State Supreme Court Data Tracker
Use this data to spot trends, anticipate what’s next, and supercharge your advocacy.
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State v. Brown, 201 A.3d 77 (N.J. 2019)
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New Jersey | 2019 | Criminal Justice, Access to Justice |
State:
New Jersey
Year:
2019
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingTracy Crews was shot three times while on the first floor of a Trenton home and exited the front door of the home before collapsing in the street. Prior to his death, Crews stated that the Defendants, Brown and Dawson, did this to him. One week after Defendants’ murder trial began, after counsel made opening statements and examined four of the State’s witnesses, the prosecutor turned over to defense counsel 19 reports that were in the State’s possession but had not previously been provided to the Defendants. The Defendants moved to dismiss the indictment with prejudice. The trial court rejected the dismissal motion and the court made several significant evidentiary rulings. At the conclusion of the trial, the Defendants were found guilty of murder. The appellate court affirmed the trial court's ruling, but the Supreme Court disagreed, holding that the State's failure to produce nineteen discovery items until one week after the beginning of the murder trial violated Defendants’ due process rights under Brady v. Maryland, 373 U.S. 83 (1963). Though there was no evidence or allegation that the State acted in bad faith or intentionally in failing to timely produce the discoverable material, the Court reversed the judgment of the Appellate Division, vacated Defendants’ convictions, and remanded for a new trial because Defendants were deprived of a fair trial.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Tracy Crews was shot three times while on the first floor of a Trenton home and exited the front door of the home before collapsing in the street. Prior to his death, Crews stated that the Defendants, Brown and Dawson, did this to him. One week after Defendants’ murder trial began, after counsel made opening statements and examined four of the State’s witnesses, the prosecutor turned over to defense counsel 19 reports that were in the State’s possession but had not previously been provided to the Defendants. The Defendants moved to dismiss the indictment with prejudice. The trial court rejected the dismissal motion and the court made several significant evidentiary rulings. At the conclusion of the trial, the Defendants were found guilty of murder. The appellate court affirmed the trial court's ruling, but the Supreme Court disagreed, holding that the State's failure to produce nineteen discovery items until one week after the beginning of the murder trial violated Defendants’ due process rights under Brady v. Maryland, 373 U.S. 83 (1963). Though there was no evidence or allegation that the State acted in bad faith or intentionally in failing to timely produce the discoverable material, the Court reversed the judgment of the Appellate Division, vacated Defendants’ convictions, and remanded for a new trial because Defendants were deprived of a fair trial.
Link to Opinion
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State v. Brown, 945 N.W.2d 584 (Wis. 2020)
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Wisconsin | 2020 | Criminal Justice, Police Misconduct and Bias |
State:
Wisconsin
Year:
2020
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant moved to suppress drugs and money found during a search. The search occurred during a traffic stop, when the police asked the Defendant to step out of the vehicle, moved him to the front of the squad care, and searched his person. The Supreme Court affirmed the denial of Defendant’s motion, concluding that the Defendant’s prior offenses for drug crimes and armed robbery, combined with the Defendant's statement that his destination was "nowhere really" and that he was coming from Milwaukee, which the officers identified as a source city for drugs, gave rise to reasonable suspicion, such that the search was proper.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant moved to suppress drugs and money found during a search. The search occurred during a traffic stop, when the police asked the Defendant to step out of the vehicle, moved him to the front of the squad care, and searched his person. The Supreme Court affirmed the denial of Defendant’s motion, concluding that the Defendant’s prior offenses for drug crimes and armed robbery, combined with the Defendant's statement that his destination was "nowhere really" and that he was coming from Milwaukee, which the officers identified as a source city for drugs, gave rise to reasonable suspicion, such that the search was proper.
Link to Opinion
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State v. Buckner, 738 S.E.2d 65 (Ga. 2013)
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Georgia | 2013 | Criminal Justice, Access to Justice, Death Penalty |
State:
Georgia
Year:
2013
Topics:
Criminal Justice, Access to Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was indicted for kidnapping, molestation, and murder of a 12-year old. Four years later, Defendant had still not been brought to trial, so he filed a motion to dismiss the indictment. The trial court granted the motion and the State appealed, contending that the trial court misapplied Barker v. Wingo, 407 U.S. 514 (1972), and Doggett v. United States, 505 U.S. 647 (1992), which 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 Supreme Court disagreed and affirmed the trial court's order. More than 53 months elapsed between the indictment and the dismissal, an uncommonly long delay and much of the delay was attributable to the negligent inaction of the prosecuting attorneys or to reassignment of the case from one prosecuting attorney to another. Further, the delay was occasioned by the prosecuting attorney's eventual announcement that the State intended to seek the death penalty, made on the day the case was set for trial for the tenth time. The trial court expressed concern that the late decision to seek the death penalty was not made upon the discovery of new evidence “or information equally notable, that would cause a reasonable prosecutor in a case to reconsider the issue of punishment, even late in the prosecution of a case.” Instead, the trial court found that the prosecuting attorneys were aware, or should have been aware, of all of the evidence against Defendant long before they decided to seek the death penalty. Defendant suffered actual prejudice as a result of his inability to show the extent to which evidence tampering occurred, due to an officer's inability to recall important details of the investigation with the passage of time. In weighing the Barker-Doggett factors, the Supreme Court is committed to the substantial discretion of the trial court, and “its ultimate judgment is reviewed on appeal only for an abuse of that discretion.” Finding no abuse of discretion, the Supreme Court affirmed the trial court's judgment.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was indicted for kidnapping, molestation, and murder of a 12-year old. Four years later, Defendant had still not been brought to trial, so he filed a motion to dismiss the indictment. The trial court granted the motion and the State appealed, contending that the trial court misapplied Barker v. Wingo, 407 U.S. 514 (1972), and Doggett v. United States, 505 U.S. 647 (1992), which 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 Supreme Court disagreed and affirmed the trial court's order. More than 53 months elapsed between the indictment and the dismissal, an uncommonly long delay and much of the delay was attributable to the negligent inaction of the prosecuting attorneys or to reassignment of the case from one prosecuting attorney to another. Further, the delay was occasioned by the prosecuting attorney's eventual announcement that the State intended to seek the death penalty, made on the day the case was set for trial for the tenth time. The trial court expressed concern that the late decision to seek the death penalty was not made upon the discovery of new evidence “or information equally notable, that would cause a reasonable prosecutor in a case to reconsider the issue of punishment, even late in the prosecution of a case.” Instead, the trial court found that the prosecuting attorneys were aware, or should have been aware, of all of the evidence against Defendant long before they decided to seek the death penalty. Defendant suffered actual prejudice as a result of his inability to show the extent to which evidence tampering occurred, due to an officer's inability to recall important details of the investigation with the passage of time. In weighing the Barker-Doggett factors, the Supreme Court is committed to the substantial discretion of the trial court, and “its ultimate judgment is reviewed on appeal only for an abuse of that discretion.” Finding no abuse of discretion, the Supreme Court affirmed the trial court's judgment.
Link to Opinion
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State v. Bullock, 805 S.E.2d 671 (N.C. 2017)
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North Carolina | 2017 | Criminal Justice |
State:
North Carolina
Year:
2017
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDuring a traffic stop, police officers spoke with the Defendant while performing database checks and other functions of the traffic stop. The officers believed the Defendant was making contradictory statements, received consent to search the car, and then found heroin in the car the Defendant was driving. At trial the Defendant argued that the search violated the Fourth Amendment's prohibition on unreasonable searches and seizures because the traffic stop was unlawfully prolonged. The Defendant moved to suppress the evidence. The trial court denied the motion. The court of appeals reversed, finding that the officers did unlawfully prolong the traffic stop under the standard set forth by the U.S. Supreme Court in Rodriguez v. United States, 575 U.S. 348 (2015). Under Rodriguez, a traffic stop cannot extend beyond the length of time that is "reasonably necessary" to accomplish the mission of the stop. The Supreme Court reversed the decision of the court of appeal. The Supreme Court held that the reasonable duration of a traffic stop "includes more than just the time needed to write a ticket." The Supreme Court also found that the officers had a reasonable suspicion of criminal activity based on their conversation with the Defendant and therefore did not unconstitutionally prolong the traffic stop under Rodriguez.
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Justice Vote Breakdown
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Summary of Case Context & Holding
During a traffic stop, police officers spoke with the Defendant while performing database checks and other functions of the traffic stop. The officers believed the Defendant was making contradictory statements, received consent to search the car, and then found heroin in the car the Defendant was driving. At trial the Defendant argued that the search violated the Fourth Amendment's prohibition on unreasonable searches and seizures because the traffic stop was unlawfully prolonged. The Defendant moved to suppress the evidence. The trial court denied the motion. The court of appeals reversed, finding that the officers did unlawfully prolong the traffic stop under the standard set forth by the U.S. Supreme Court in Rodriguez v. United States, 575 U.S. 348 (2015). Under Rodriguez, a traffic stop cannot extend beyond the length of time that is "reasonably necessary" to accomplish the mission of the stop. The Supreme Court reversed the decision of the court of appeal. The Supreme Court held that the reasonable duration of a traffic stop "includes more than just the time needed to write a ticket." The Supreme Court also found that the officers had a reasonable suspicion of criminal activity based on their conversation with the Defendant and therefore did not unconstitutionally prolong the traffic stop under Rodriguez.
Link to Opinion
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State v. Burch, 961 N.W.2d 314 (Wis. 2021)
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Wisconsin | 2021 | Criminal Justice, Police Misconduct and Bias |
State:
Wisconsin
Year:
2021
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of first degree intentional homicide. Defendant appealed on the grounds that incriminating cell-phone data should have been suppressed. The police obtained the data during a consensual search of Defendant’s phone. Defendant argues that he gave the police permission to download his text messages, but that they then also discovered his gmail address. The police used the gmail address to obtain a search warrant for information about the Defendant from Google. In response to the search warrant, Google provided location information about the Defendant's cell phone, which placed him near the scene of the murder at the time of the murder. The Supreme Court held that the exclusionary rule, where evidence obtained in violation of the Fourth Amendment may not be admitted into evidence against a criminal defendant, did not apply in this situation because the police misconduct, if any even occurred, was negligent at worst. The Defendant had signed a form giving the police consent to search his cell phone, and the form did not place any limitation on the scope of consent.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of first degree intentional homicide. Defendant appealed on the grounds that incriminating cell-phone data should have been suppressed. The police obtained the data during a consensual search of Defendant’s phone. Defendant argues that he gave the police permission to download his text messages, but that they then also discovered his gmail address. The police used the gmail address to obtain a search warrant for information about the Defendant from Google. In response to the search warrant, Google provided location information about the Defendant's cell phone, which placed him near the scene of the murder at the time of the murder. The Supreme Court held that the exclusionary rule, where evidence obtained in violation of the Fourth Amendment may not be admitted into evidence against a criminal defendant, did not apply in this situation because the police misconduct, if any even occurred, was negligent at worst. The Defendant had signed a form giving the police consent to search his cell phone, and the form did not place any limitation on the scope of consent.
Link to Opinion
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State v. Burke, 843 S.E.2d 246 (N.C. 2020)
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North Carolina | 2020 | Criminal Justice, Death Penalty |
State:
North Carolina
Year:
2020
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDeath row Defendant's Racial Justice Act (RJA) motion was dismissed following the Act's repeal. The RJA permitted capital defendants to challenge their death sentences if they can prove that the decision, during their trials, to seek or impose the death penalty was racially motivated. However, the RJA was subsequently repealed. The Supreme Court held that—pursuant to State v. Ramseur, 843 S.E.2d 106 (N.C. 2020) which dealt with the same repeal of the RJA and similar factual issues—the dismissal of the RJA claim was unconstitutional. In Ramsuer, the Supreme Court decided that the repeal of the RJA could not be applied retroactively to pending claims under the RJA. As such, the dismissal of the Defendant's pending claim was improper.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Death row Defendant's Racial Justice Act (RJA) motion was dismissed following the Act's repeal. The RJA permitted capital defendants to challenge their death sentences if they can prove that the decision, during their trials, to seek or impose the death penalty was racially motivated. However, the RJA was subsequently repealed. The Supreme Court held that—pursuant to State v. Ramseur, 843 S.E.2d 106 (N.C. 2020) which dealt with the same repeal of the RJA and similar factual issues—the dismissal of the RJA claim was unconstitutional. In Ramsuer, the Supreme Court decided that the repeal of the RJA could not be applied retroactively to pending claims under the RJA. As such, the dismissal of the Defendant's pending claim was improper.
Link to Opinion
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State v. Burns, 344 P.3d 303 (Ariz. 2015)
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2015 | Criminal Justice, Police Misconduct and Bias, Death Penalty |
State:
Year:
2015
Topics:
Criminal Justice, Police Misconduct and Bias, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of first-degree murder, sexual assault, kidnapping, and misconduct involving weapons and was sentenced to death for shooting and killing a woman after going on a date with her. The victim’s shirt, bra, and underwear were found the day after the date in an apartment complex dumpster. Semen found on the victim’s underwear matched Defendant’s DNA. Police searched Defendant’s home and vehicles after his arrest and found a pair of men’s jeans with the victim’s blood in one car and the victim’s earring in his other vehicle. They also found a case for a handgun in his home. The victim’s body was found a few weeks later and a swab taken from her body matched Defendant’s DNA. Cellphone records confirmed Defendant had been in the area where the victim’s body was found the night of the murder. Defendant argued 26 different issues on appeal including error in failing to sever charges, error in admission of statements by Defendant’s fiancée during trial, error in failing to permit certain statements and witnesses, error in admission of evidence of prior conduct in penalty phase, as well as juror and prosecutorial misconduct. The Supreme Court affirmed Defendant’s convictions and death sentence, deferring to the trial court or jury on nearly all of the issues and ruling neither abused their discretion. The Court only found abuse of discretion on one issue: whether the charges should have been severed for trial. The Court ruled that the sexual assault, murder, and kidnapping charges were all properly joined as part of a common scheme or plan. However, the Court was “troubled” by the failure to sever the misconduct involving the weapons charge because it required introduction of evidence of Defendant’s prior felony charges, which would not otherwise have been included. Therefore, the Court held that inclusion of that charge was an abuse of discretion and the prejudice was not adequately mitigated by the instruction that jurors consider each offense separately. However, the Court found the error was harmless because the evidence of guilt was overwhelming. The Court instructed courts in future cases to prevent this situation due to the risk of potential prejudice.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of first-degree murder, sexual assault, kidnapping, and misconduct involving weapons and was sentenced to death for shooting and killing a woman after going on a date with her. The victim’s shirt, bra, and underwear were found the day after the date in an apartment complex dumpster. Semen found on the victim’s underwear matched Defendant’s DNA. Police searched Defendant’s home and vehicles after his arrest and found a pair of men’s jeans with the victim’s blood in one car and the victim’s earring in his other vehicle. They also found a case for a handgun in his home. The victim’s body was found a few weeks later and a swab taken from her body matched Defendant’s DNA. Cellphone records confirmed Defendant had been in the area where the victim’s body was found the night of the murder. Defendant argued 26 different issues on appeal including error in failing to sever charges, error in admission of statements by Defendant’s fiancée during trial, error in failing to permit certain statements and witnesses, error in admission of evidence of prior conduct in penalty phase, as well as juror and prosecutorial misconduct. The Supreme Court affirmed Defendant’s convictions and death sentence, deferring to the trial court or jury on nearly all of the issues and ruling neither abused their discretion. The Court only found abuse of discretion on one issue: whether the charges should have been severed for trial. The Court ruled that the sexual assault, murder, and kidnapping charges were all properly joined as part of a common scheme or plan. However, the Court was “troubled” by the failure to sever the misconduct involving the weapons charge because it required introduction of evidence of Defendant’s prior felony charges, which would not otherwise have been included. Therefore, the Court held that inclusion of that charge was an abuse of discretion and the prejudice was not adequately mitigated by the instruction that jurors consider each offense separately. However, the Court found the error was harmless because the evidence of guilt was overwhelming. The Court instructed courts in future cases to prevent this situation due to the risk of potential prejudice.
Link to Opinion
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State v. Bursell, 827 S.E.2d 302 (N.C. 2019)
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North Carolina | 2019 | Criminal Justice |
State:
North Carolina
Year:
2019
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted at trial of statutory rape. The state requested that the court order the Defendant to be part of a satellite based monitoring program for the rest of his life and the Defendant did not raise the issue of whether such an order violated his Fourth Amendment rights against unreasonable searches. The trial court ordered the Defendant to enroll in the program upon his release from prison. When the Defendant appealed the order on Fourth Amendment grounds the court of appeals held that it had jurisdiction to hear the claim even if the Defendant had not preserved the claim. The Supreme Court held that the Defendant had failed to preserve the claim that the court-ordered satellite based monitoring constituted an unreasonable search and seizure under the Fourth Amendment by not raising the claim at trial. However, the Supreme Court held that the appellate court was within its discretion to suspend the appellate rules and review the unpreserved claim because the rules of appellate procedure in North Carolina give appeals courts discretion to suspend the appellate rules, which otherwise prohibit raising the unpreserved claim. As a result the Supreme Court affirmed the appellate court's decision to vacate the trial court's order.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted at trial of statutory rape. The state requested that the court order the Defendant to be part of a satellite based monitoring program for the rest of his life and the Defendant did not raise the issue of whether such an order violated his Fourth Amendment rights against unreasonable searches. The trial court ordered the Defendant to enroll in the program upon his release from prison. When the Defendant appealed the order on Fourth Amendment grounds the court of appeals held that it had jurisdiction to hear the claim even if the Defendant had not preserved the claim. The Supreme Court held that the Defendant had failed to preserve the claim that the court-ordered satellite based monitoring constituted an unreasonable search and seizure under the Fourth Amendment by not raising the claim at trial. However, the Supreme Court held that the appellate court was within its discretion to suspend the appellate rules and review the unpreserved claim because the rules of appellate procedure in North Carolina give appeals courts discretion to suspend the appellate rules, which otherwise prohibit raising the unpreserved claim. As a result the Supreme Court affirmed the appellate court's decision to vacate the trial court's order.
Link to Opinion
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State v. Burton, 878 S.E.2d 515 (Ga. 2022)
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Georgia | 2022 | Criminal Justice, Juvenile Justice |
State:
Georgia
Year:
2022
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe trial court found that Defendant “shook his head” while saying, “Yeah, I don't want to,” and that after Defendant responded to the detective after she advised Defendant of his rights under Miranda, Defendant “appeared to shrug . . . and his body language was not that of an individual who seemed open to conversation.” The Supreme Court held that the trial court did not err in granting Defendant's motion to suppress statements made to law enforcement after placing great weight in particular on the factors of Defendant's age of 16, the length of the interview, law enforcement's failure to inform Defendant of the charges against him or that an arrest warrant had already been obtained for him, and the absence of either of Defendant's parents. In the context of evaluating whether juveniles have waived their rights under Miranda, the Supreme Court has held that the question of a voluntary and knowing waiver “depends on the totality of the circumstances and the state has a heavy burden in showing that the juvenile did understand and waive his rights.” The Supreme Court has identified the nine Riley factors to consider in evaluating whether a juvenile has knowingly and intelligently waived his rights under Miranda. The nine Riley factors are: "(1) age of the accused; (2) education of the accused; (3) knowledge of the accused as to both the substance of the charge . . . and the nature of his rights to consult with an attorney and remain silent; (4) whether the accused is held incommunicado or allowed to consult with relatives, friends or an attorney; (5) whether the accused was interrogated before or after formal charges had been filed; (6) methods used in interrogations; (7) length of interrogations; (8) whether vel non the accused refused to voluntarily give statements on prior occasions; and (9) whether the accused has repudiated an extra judicial statement at a later date." Riley v. State, 226 S.E.2d 922, 926 (Ga. 1976).
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Justice Vote Breakdown
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Summary of Case Context & Holding
The trial court found that Defendant “shook his head” while saying, “Yeah, I don't want to,” and that after Defendant responded to the detective after she advised Defendant of his rights under Miranda, Defendant “appeared to shrug . . . and his body language was not that of an individual who seemed open to conversation.” The Supreme Court held that the trial court did not err in granting Defendant's motion to suppress statements made to law enforcement after placing great weight in particular on the factors of Defendant's age of 16, the length of the interview, law enforcement's failure to inform Defendant of the charges against him or that an arrest warrant had already been obtained for him, and the absence of either of Defendant's parents. In the context of evaluating whether juveniles have waived their rights under Miranda, the Supreme Court has held that the question of a voluntary and knowing waiver “depends on the totality of the circumstances and the state has a heavy burden in showing that the juvenile did understand and waive his rights.” The Supreme Court has identified the nine Riley factors to consider in evaluating whether a juvenile has knowingly and intelligently waived his rights under Miranda. The nine Riley factors are: "(1) age of the accused; (2) education of the accused; (3) knowledge of the accused as to both the substance of the charge . . . and the nature of his rights to consult with an attorney and remain silent; (4) whether the accused is held incommunicado or allowed to consult with relatives, friends or an attorney; (5) whether the accused was interrogated before or after formal charges had been filed; (6) methods used in interrogations; (7) length of interrogations; (8) whether vel non the accused refused to voluntarily give statements on prior occasions; and (9) whether the accused has repudiated an extra judicial statement at a later date." Riley v. State, 226 S.E.2d 922, 926 (Ga. 1976).
Link to Opinion
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State v. Camey, 217 A.3d 106 (N.J. 2019)
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New Jersey | 2019 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2019
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe State appealed the trial court's rulings, which were affirmed by the Appellate Division, that (1) results from a buccal swab obtained by illegal means are inadmissible under an inevitable discovery analysis; and (2) that the inevitable discovery analysis is inapplicable to a request for an application under Rule 3:5A-4 to take a second buccal swab from a defendant. The New Jersey Supreme Court held that the police violated the Fourth Amendment in the way that they obtained Defendant's DNA, and, as a result, the results from the search cannot be used. The Court explained that the taking of a buccal swab for purposes of obtaining DNA is a "search" and that a search must be conducted pursuant to a warrant or fall with an exception to the warrant requirement - such as being obtained by consent - to pass constitutional muster. The Court further explained that although the inevitable discovery analysis can be used to evaluate DNA evidence, the State did not carry its burden to show it would have used legal processes to lawfully obtain the critical information. With respect to the State's application under Rule 3:5A for an order to take a new buccal swab, the Court held that the inevitable discovery framework is not correct in these circumstances where the completed searches can be replicated. Instead, the Court derived a test using aspects of the "independent source doctrine" and held that for an application under Rule 3:5A for a new buccal swab for DNA when a previously obtained sample is declared invalid and suppressed: (1) first, the State must demonstrate that probable cause exists to conduct a new search (evidence of probable cause may involve the same evidence that existed at the time of the illegal search, with new evidence permitted but not required); (2) second, the Court must determine whether the State's showing of probable cause is untainted by the results of the prior search (i.e., the probable cause must be independent of the information obtained through the results from the prior swab); and (3) the State must show by clear and convincing evidence that the initial impermissible search was not the result of flagrant police misconduct. The Court further noted that it must consider the degree of intrusion posed by the State's second search, and that a buccal swab is minimally intrusive. The Court remanded to allow the State an opportunity to demonstrate whether it can meet the standard.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The State appealed the trial court's rulings, which were affirmed by the Appellate Division, that (1) results from a buccal swab obtained by illegal means are inadmissible under an inevitable discovery analysis; and (2) that the inevitable discovery analysis is inapplicable to a request for an application under Rule 3:5A-4 to take a second buccal swab from a defendant. The New Jersey Supreme Court held that the police violated the Fourth Amendment in the way that they obtained Defendant's DNA, and, as a result, the results from the search cannot be used. The Court explained that the taking of a buccal swab for purposes of obtaining DNA is a "search" and that a search must be conducted pursuant to a warrant or fall with an exception to the warrant requirement - such as being obtained by consent - to pass constitutional muster. The Court further explained that although the inevitable discovery analysis can be used to evaluate DNA evidence, the State did not carry its burden to show it would have used legal processes to lawfully obtain the critical information. With respect to the State's application under Rule 3:5A for an order to take a new buccal swab, the Court held that the inevitable discovery framework is not correct in these circumstances where the completed searches can be replicated. Instead, the Court derived a test using aspects of the "independent source doctrine" and held that for an application under Rule 3:5A for a new buccal swab for DNA when a previously obtained sample is declared invalid and suppressed: (1) first, the State must demonstrate that probable cause exists to conduct a new search (evidence of probable cause may involve the same evidence that existed at the time of the illegal search, with new evidence permitted but not required); (2) second, the Court must determine whether the State's showing of probable cause is untainted by the results of the prior search (i.e., the probable cause must be independent of the information obtained through the results from the prior swab); and (3) the State must show by clear and convincing evidence that the initial impermissible search was not the result of flagrant police misconduct. The Court further noted that it must consider the degree of intrusion posed by the State's second search, and that a buccal swab is minimally intrusive. The Court remanded to allow the State an opportunity to demonstrate whether it can meet the standard.
Link to Opinion
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State v. Campbell, 884 S.E.2d 674 (N.C. 2023)
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North Carolina | 2023 | Criminal Justice, Access to Justice |
State:
North Carolina
Year:
2023
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court affirmed a finding that Defendant failed to make a prima facie showing that the State used peremptory strikes against jurors for a discriminatory purpose. The Defendant was charged with making a prima facie case for discrimination by the State because the Defendant was making a Batson challenge, to the validity of the State's use of peremptory strikes, per Batson v. Kentucky, 476 U.S. 79 (1986). Defendant had argued that the State's use of three of four of its peremptory strikes against black jurors sufficiently established the prima facie case that the State was discriminating in striking jurors. However, upon review of the record, the Supreme Court affirmed the lower court's holding that the prima facie case for discrimination was not established by the ratio in light of the totality of the circumstances because the standard for disturbing the trial court's holding required that the decision be "clearly erroneous." That standard required the appellate court to be deferential to the lower court's holding, such that the higher court will only disturb the holding in "exceptional circumstances." Since the only evidence given for the prima facie case was a single mathematical ratio, the Supreme Court found that the appellate court did not err in finding the trial court's decision was not clearly erroneous.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court affirmed a finding that Defendant failed to make a prima facie showing that the State used peremptory strikes against jurors for a discriminatory purpose. The Defendant was charged with making a prima facie case for discrimination by the State because the Defendant was making a Batson challenge, to the validity of the State's use of peremptory strikes, per Batson v. Kentucky, 476 U.S. 79 (1986). Defendant had argued that the State's use of three of four of its peremptory strikes against black jurors sufficiently established the prima facie case that the State was discriminating in striking jurors. However, upon review of the record, the Supreme Court affirmed the lower court's holding that the prima facie case for discrimination was not established by the ratio in light of the totality of the circumstances because the standard for disturbing the trial court's holding required that the decision be "clearly erroneous." That standard required the appellate court to be deferential to the lower court's holding, such that the higher court will only disturb the holding in "exceptional circumstances." Since the only evidence given for the prima facie case was a single mathematical ratio, the Supreme Court found that the appellate court did not err in finding the trial court's decision was not clearly erroneous.
Link to Opinion
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State v. Carter, 255 A.3d 1139 (N.J. 2021)
State v. Roman-Rosado, 255 A.3d 1139 (N.J. 2021)
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New Jersey | 2021 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2021
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingCarter was stopped under a New Jersey statute that prohibits concealing or obscuring any markings on a license plate. On Carter's license plate, the words "Garden State" were fully covered. During the stop the police learned that Carter was driving without a license and had two outstanding warrants for his arrest. The police arrested Carter and found drugs on him. The Appellate Division rejected Carter's argument that the stop was not supported by the statute and that the drugs were therefore the fruit of an unlawful search, stating that the statute prohibits even partial concealment of any marking on a license plate, including the words "Garden State," and not only the markings composing the vehicle's registration. Roman-Rosado was also stopped under the New Jersey statute that prohibits concealing or obscuring any markings on the license plate. On Roman-Rosado's license plate, the bottom of the words "Garden State" were only 10-15% covered by a frame. During the stop the police learned that Roman-Rosado was driving without a license and had two outstanding warrants for his arrest. The police arrested Roman-Rosado and found an unloaded handgun in the car which he did not have a permit for. Roman-Rosado pled guilty to unlawful possession of a weapon, but the Appellate Division reversed his conviction, holding that the search of the car was unlawful because the slight obscuring of the words "Garden State" did not violate the statute prohibiting obstruction of license plate markings. The issue presented to the New Jersey Supreme Court in both cases was whether the New Jersey statute prohibiting concealment of markings on the license plate was unconstitutional due to failing the rational basis test, and whether it was unconstitutionally vague and overly broad. The Supreme Court held that, under a narrow interpretation of the law (applying the doctrine of constitutional avoidance), the statute is not unconstitutional, but it must be interpreted to ask whether license plate markings are legible or identifiable from the perspective of an objectively reasonable person. The Court reasoned that a broad reading of the law could raise serious constitutional concerns and invite pretextual stops, while leading to arbitrary and discriminatory enforcement. Therefore, the Court found that the law should be interpreted narrowly to avoid the constitutional issue. The Court reversed in Carter and affirmed in Roman-Rosado.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Carter was stopped under a New Jersey statute that prohibits concealing or obscuring any markings on a license plate. On Carter's license plate, the words "Garden State" were fully covered. During the stop the police learned that Carter was driving without a license and had two outstanding warrants for his arrest. The police arrested Carter and found drugs on him. The Appellate Division rejected Carter's argument that the stop was not supported by the statute and that the drugs were therefore the fruit of an unlawful search, stating that the statute prohibits even partial concealment of any marking on a license plate, including the words "Garden State," and not only the markings composing the vehicle's registration. Roman-Rosado was also stopped under the New Jersey statute that prohibits concealing or obscuring any markings on the license plate. On Roman-Rosado's license plate, the bottom of the words "Garden State" were only 10-15% covered by a frame. During the stop the police learned that Roman-Rosado was driving without a license and had two outstanding warrants for his arrest. The police arrested Roman-Rosado and found an unloaded handgun in the car which he did not have a permit for. Roman-Rosado pled guilty to unlawful possession of a weapon, but the Appellate Division reversed his conviction, holding that the search of the car was unlawful because the slight obscuring of the words "Garden State" did not violate the statute prohibiting obstruction of license plate markings. The issue presented to the New Jersey Supreme Court in both cases was whether the New Jersey statute prohibiting concealment of markings on the license plate was unconstitutional due to failing the rational basis test, and whether it was unconstitutionally vague and overly broad. The Supreme Court held that, under a narrow interpretation of the law (applying the doctrine of constitutional avoidance), the statute is not unconstitutional, but it must be interpreted to ask whether license plate markings are legible or identifiable from the perspective of an objectively reasonable person. The Court reasoned that a broad reading of the law could raise serious constitutional concerns and invite pretextual stops, while leading to arbitrary and discriminatory enforcement. Therefore, the Court found that the law should be interpreted narrowly to avoid the constitutional issue. The Court reversed in Carter and affirmed in Roman-Rosado.
Link to Opinion
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State v. Carter, 739 S.E.2d 548 (N.C. 2013)
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North Carolina | 2013 | Criminal Justice |
State:
North Carolina
Year:
2013
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAfter a jury trial, Defendant was convicted of first-degree sexual offense based on insertion of male sex organ into the mouth of the alleged victim and first-degree sexual offense based on insertion of the male sex organ into the anus of the alleged victim (who was the Defendant's then eight-year old stepdaughter). The court of appeals held that the trial court's failure to give an instruction on the lesser-included offense of attempted first-degree sexual offense with respect to the second offence of insertion of the male sex organ into the anus of the alleged victim was plain error and granted a new trial with respect to the second offense. The Supreme Court reversed the court of appeals and reinstated the trial court's judgment, holding that Defendant failed to show plain error under the standard set forth in State v. Lawrence, 723 S.E.2d 326 (N.C. 2012), which stated that for an error to constitute plain error, a defendant must demonstrate that a fundamental error occurred at trial. That Supreme Court also stated that for an error to be fundamental, a defendant must establish prejudice, meaning that, after examination of the entire record, the error had a probable impact on the jury's finding that the defendant was guilty.
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Justice Vote Breakdown
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Summary of Case Context & Holding
After a jury trial, Defendant was convicted of first-degree sexual offense based on insertion of male sex organ into the mouth of the alleged victim and first-degree sexual offense based on insertion of the male sex organ into the anus of the alleged victim (who was the Defendant's then eight-year old stepdaughter). The court of appeals held that the trial court's failure to give an instruction on the lesser-included offense of attempted first-degree sexual offense with respect to the second offence of insertion of the male sex organ into the anus of the alleged victim was plain error and granted a new trial with respect to the second offense. The Supreme Court reversed the court of appeals and reinstated the trial court's judgment, holding that Defendant failed to show plain error under the standard set forth in State v. Lawrence, 723 S.E.2d 326 (N.C. 2012), which stated that for an error to constitute plain error, a defendant must demonstrate that a fundamental error occurred at trial. That Supreme Court also stated that for an error to be fundamental, a defendant must establish prejudice, meaning that, after examination of the entire record, the error had a probable impact on the jury's finding that the defendant was guilty.
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State v. Cassidy, 197 A.3d 86 (N.J. 2018)
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New Jersey | 2018 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2018
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 2008, in State v. Chun, 943 A.2d 114 (N.J. 2008), the New Jersey Supreme Court found the results of the Alcotest machine, which analyzes breath samples, admissible in DWI cases to establish a defendant's guilt or innocence, and required that the devices be recalibrated semi-annually to help ensure accurate measurements. The individual tasked with performing the semi-annual calibrations, Marc Dennis, failed to do so, and was ultimately charged with neglecting to take required measurements and having falsely certified that he followed the calibration procedures. Dennis was indicted in 2016 for his failure to use a thermometer that produces temperature measurements traceable to the standards set by the National Institute of Standards and Technology (NIST). The Attorney General's Office notified the Courts that evidentiary breath samples from over 20,000 people were procured using Alcotest machines calibrated by Dennis. One such individual, Defendant Cassidy pled guilty to driving under the influence solely on the basis of an Alcotest showing her blood alcohol level exceeded the legal limit. Cassidy moved to withdraw her guilty plea, and the Attorney General moved for direct certification. The New Jersey Supreme Court granted the motion and remanded the case to the retired Appellate Division Presiding Judge as a Special Master to determine whether the failure to test the simulator solutions with NIST-traceable digital thermometers before calibrating an Alcotest would undermine or call into question the reliability of the tests. The Special Master issued a 198-page report, concluding that failure to use a thermometer that produces NIST-traceable temperature readings undermines the reliability of the Alcotest. The New Jersey Supreme Court adopted the Special Master's findings, and ordered the State to notify all affected defendants of the decision so that they may take appropriate action—opening the gates for thousands of individuals convicted of driving while intoxicated based on an Alcotest reading of above .08 to file for post-conviction relief.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 2008, in State v. Chun, 943 A.2d 114 (N.J. 2008), the New Jersey Supreme Court found the results of the Alcotest machine, which analyzes breath samples, admissible in DWI cases to establish a defendant's guilt or innocence, and required that the devices be recalibrated semi-annually to help ensure accurate measurements. The individual tasked with performing the semi-annual calibrations, Marc Dennis, failed to do so, and was ultimately charged with neglecting to take required measurements and having falsely certified that he followed the calibration procedures. Dennis was indicted in 2016 for his failure to use a thermometer that produces temperature measurements traceable to the standards set by the National Institute of Standards and Technology (NIST). The Attorney General's Office notified the Courts that evidentiary breath samples from over 20,000 people were procured using Alcotest machines calibrated by Dennis. One such individual, Defendant Cassidy pled guilty to driving under the influence solely on the basis of an Alcotest showing her blood alcohol level exceeded the legal limit. Cassidy moved to withdraw her guilty plea, and the Attorney General moved for direct certification. The New Jersey Supreme Court granted the motion and remanded the case to the retired Appellate Division Presiding Judge as a Special Master to determine whether the failure to test the simulator solutions with NIST-traceable digital thermometers before calibrating an Alcotest would undermine or call into question the reliability of the tests. The Special Master issued a 198-page report, concluding that failure to use a thermometer that produces NIST-traceable temperature readings undermines the reliability of the Alcotest. The New Jersey Supreme Court adopted the Special Master's findings, and ordered the State to notify all affected defendants of the decision so that they may take appropriate action—opening the gates for thousands of individuals convicted of driving while intoxicated based on an Alcotest reading of above .08 to file for post-conviction relief.
Link to Opinion
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State v. Castagnola, 46 N.E.3d 638 (Ohio 2015)
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Ohio | 2015 | Criminal Justice, Police Misconduct and Bias |
State:
Ohio
Year:
2015
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA prosecutor charged the Defendant with selling alcohol to minors and a police source revealed that the Defendant damaged the prosecutor's vehicles in response. The patrolman had the source wear a concealed recording device and recorded a conversation with the Defendant where the Defendant stated that he found the prosecutor's address by searching online. A detective thereafter used this evidence to request an arrest warrant and search warrant, but did not indicate in the search warrant that the Defendant conducted the online search of the prosecutor's address with a computer located in the Defendant's home. The judge granted the warrants repeating the detective's description, which resulted in the seizure of numerous items, including two computers. The Supreme Court held that a detective had made an illicit/unwarranted inference in a search warrant and that there was no probable cause for investigation because the inference that the Defendant searched for the address online on his computer was presented as a fact in the detective's affidavit requesting a warrant and thus usurped the magistrate's inference-drawing authority and the details regarding the records and documents stored on the computer were not included and thus the search warrant was not sufficiently particularized.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A prosecutor charged the Defendant with selling alcohol to minors and a police source revealed that the Defendant damaged the prosecutor's vehicles in response. The patrolman had the source wear a concealed recording device and recorded a conversation with the Defendant where the Defendant stated that he found the prosecutor's address by searching online. A detective thereafter used this evidence to request an arrest warrant and search warrant, but did not indicate in the search warrant that the Defendant conducted the online search of the prosecutor's address with a computer located in the Defendant's home. The judge granted the warrants repeating the detective's description, which resulted in the seizure of numerous items, including two computers. The Supreme Court held that a detective had made an illicit/unwarranted inference in a search warrant and that there was no probable cause for investigation because the inference that the Defendant searched for the address online on his computer was presented as a fact in the detective's affidavit requesting a warrant and thus usurped the magistrate's inference-drawing authority and the details regarding the records and documents stored on the computer were not included and thus the search warrant was not sufficiently particularized.
Link to Opinion
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State v. Chafee, 332 P.3d 240 (Mont. 2014)
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Montana | 2014 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2014
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was charged with accountability for arson and accountability for theft (charges in Montana where a person is responsible for conduct that is an element of an offense if the conduct is that of another and the person is legally accountable for the conduct) after she had been present when her boyfriend broke into a car and lit it on fire. Defense counsel failed to offer a “mere presence” jury instruction after having argued that mere presence was insufficient to establish that Defendant was involved in the crime. A “mere presence” instruction informs the jury that mere presence at the scene of the crime and knowledge that a crime is being committed is insufficient to establish that a criminal defendant was involved in a crime. On appeal, Defendant brought an ineffective assistance of counsel claim due to the failure of counsel to offer a “mere presence" instruction. The Court held that defense counsel’s failure to offer such a “potentially beneficial instruction” constituted deficient performance. The Court also explained that “mere presence at the scene of a crime is not enough to establish accountability, [although] the accused need not take an active part in any overt criminal acts to be adjudged criminally liable for the acts." Moreover, the Court emphasized that the defense’s theory of the case was that Defendant’s mere appearance at the crime scene was insufficient to support a conviction. Because defense counsel failed to offer such an instruction, the jury was not given the chance to consider whether Defendant’s theory of the case was legally correct. The Court vacated the judgment and remanded the case for a new trial.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was charged with accountability for arson and accountability for theft (charges in Montana where a person is responsible for conduct that is an element of an offense if the conduct is that of another and the person is legally accountable for the conduct) after she had been present when her boyfriend broke into a car and lit it on fire. Defense counsel failed to offer a “mere presence” jury instruction after having argued that mere presence was insufficient to establish that Defendant was involved in the crime. A “mere presence” instruction informs the jury that mere presence at the scene of the crime and knowledge that a crime is being committed is insufficient to establish that a criminal defendant was involved in a crime. On appeal, Defendant brought an ineffective assistance of counsel claim due to the failure of counsel to offer a “mere presence" instruction. The Court held that defense counsel’s failure to offer such a “potentially beneficial instruction” constituted deficient performance. The Court also explained that “mere presence at the scene of a crime is not enough to establish accountability, [although] the accused need not take an active part in any overt criminal acts to be adjudged criminally liable for the acts." Moreover, the Court emphasized that the defense’s theory of the case was that Defendant’s mere appearance at the crime scene was insufficient to support a conviction. Because defense counsel failed to offer such an instruction, the jury was not given the chance to consider whether Defendant’s theory of the case was legally correct. The Court vacated the judgment and remanded the case for a new trial.
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State v. Chambers, 474 P.3d 1268 (Mont. 2020)
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Montana | 2020 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2020
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was charged in 2012 with burglary and theft of more than $800 from gambling machines. Unrelated to this burglary and theft charge, Defendant was previously arrested and detained in a different county for nine burglaries related to multiple unrelated break-ins and was sentenced to eight concurrent 20-year prison sentences related to these crimes in 2013. In 2017, almost 5 years after his gambling machines theft arrest, Defendant had still not been brought to trial. The Court discussed that a criminal defendant's right to a speedy trial is guaranteed by both the United States and Montana Constitutions. If the delay between accusation and trial exceeds 200 days, a speedy trial claim is evaluated by balancing four factors: (1) the length of the delay; (2) the reasons for the delay; (3) the accused's responses to the delay; and (4) prejudice to the accused. No one factor is dispositive by itself and the factors must be balanced and the unique facts and circumstances of each case must be considered to determine whether the accused has been denied their right to a speedy trial. The Court also noted that Defendant was eligible for parole for the unrelated charges in February 2018 and that the charges affected his parole eligibility. The Court held that the district court erred in denying Defendant's motion to dismiss for a speedy-trial violation because he was denied his right to a speedy trial under both the United States and Montana Constitutions since the lengthy five-year pretrial delay was excessive and unnecessary, the State made no effort, other than lodging a detainer (a notice filed where the prisoner is serving his sentence advising that he is facing pending criminal charges in another jurisdiction), to bring Defendant to trial in a timely manner, Defendant filed a motion to dismiss for speedy trial violations prior to trial, and he was presumptively prejudiced by the delay. The Court dismissed the charges against the Defendant.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was charged in 2012 with burglary and theft of more than $800 from gambling machines. Unrelated to this burglary and theft charge, Defendant was previously arrested and detained in a different county for nine burglaries related to multiple unrelated break-ins and was sentenced to eight concurrent 20-year prison sentences related to these crimes in 2013. In 2017, almost 5 years after his gambling machines theft arrest, Defendant had still not been brought to trial. The Court discussed that a criminal defendant's right to a speedy trial is guaranteed by both the United States and Montana Constitutions. If the delay between accusation and trial exceeds 200 days, a speedy trial claim is evaluated by balancing four factors: (1) the length of the delay; (2) the reasons for the delay; (3) the accused's responses to the delay; and (4) prejudice to the accused. No one factor is dispositive by itself and the factors must be balanced and the unique facts and circumstances of each case must be considered to determine whether the accused has been denied their right to a speedy trial. The Court also noted that Defendant was eligible for parole for the unrelated charges in February 2018 and that the charges affected his parole eligibility. The Court held that the district court erred in denying Defendant's motion to dismiss for a speedy-trial violation because he was denied his right to a speedy trial under both the United States and Montana Constitutions since the lengthy five-year pretrial delay was excessive and unnecessary, the State made no effort, other than lodging a detainer (a notice filed where the prisoner is serving his sentence advising that he is facing pending criminal charges in another jurisdiction), to bring Defendant to trial in a timely manner, Defendant filed a motion to dismiss for speedy trial violations prior to trial, and he was presumptively prejudiced by the delay. The Court dismissed the charges against the Defendant.
Link to Opinion
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State v. Champagne, 447 P.3d 297 (Ariz. 2019)
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Arizona | 2019 | Civil Rights, Criminal Justice, Death Penalty |
State:
Arizona
Year:
2019
Topics:
Civil Rights, Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingChampagne was convicted of first-degree murder of a man and his girlfriend. He was sentenced to death and appealed his conviction on numerous grounds, including the trial court's denial of his motion for new counsel and its instruction that the defendant might be eligible for parole when he was not. Primarily, the Defendant argued that the trial court abused its discretion by refusing to suppress incriminating statements made to an undercover detective while he was incarcerated. The Court concluded that no Miranda violation occurred because the Defendant was unaware he was speaking to a detective, and he spoke voluntarily. The Court also concluded that Defendant was not prejudiced by limiting the cross examination of a co-defendant turned cooperating witness concerning her mental health diagnoses. Further, the trial court did not err in giving a voluntary intoxication instruction where significant evidence of the Defendant's intoxication was introduced at trial, and failure to give such an instruction could lead the jury to believe that his intoxication negated the intent required for criminal liability. Finally, any error in permitting counsel to make additional arguments following a jury question during deliberation was harmless. As to the death penalty, the Court rejected the argument that Arizona's scheme violated the Eighth and Fourteenth Amendments, and rejected a number of arguments concerning mitigation evidence, affirming Defendant's conviction and sentences.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Champagne was convicted of first-degree murder of a man and his girlfriend. He was sentenced to death and appealed his conviction on numerous grounds, including the trial court's denial of his motion for new counsel and its instruction that the defendant might be eligible for parole when he was not. Primarily, the Defendant argued that the trial court abused its discretion by refusing to suppress incriminating statements made to an undercover detective while he was incarcerated. The Court concluded that no Miranda violation occurred because the Defendant was unaware he was speaking to a detective, and he spoke voluntarily. The Court also concluded that Defendant was not prejudiced by limiting the cross examination of a co-defendant turned cooperating witness concerning her mental health diagnoses. Further, the trial court did not err in giving a voluntary intoxication instruction where significant evidence of the Defendant's intoxication was introduced at trial, and failure to give such an instruction could lead the jury to believe that his intoxication negated the intent required for criminal liability. Finally, any error in permitting counsel to make additional arguments following a jury question during deliberation was harmless. As to the death penalty, the Court rejected the argument that Arizona's scheme violated the Eighth and Fourteenth Amendments, and rejected a number of arguments concerning mitigation evidence, affirming Defendant's conviction and sentences.
Link to Opinion
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State v. Chapman, 170 N.E.3d 6 (Ohio 2020)
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Ohio | 2020 | Criminal Justice |
State:
Ohio
Year:
2020
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA man was convicted for failing to pay child support to the mothers of his 11 children and sentenced to community control. One of the conditions of community control imposed by the court was that the man “make all reasonable efforts to avoid impregnating a woman” during his sentence. Chapman, the Defendant, appealed, arguing that the condition was not reasonably related to a rehabilitative purpose and because it violated his constitutional right to procreate. On appeal, the Supreme Court noted that there is no question that procreating is a fundamental right and the condition limited that right. Thus, the crucial question, the court explained was how "to review conditions of sentencing that limit a fundamental right. The Supreme Court held that the procreation prohibition was not reasonably related to the goals of community control, nor was it reasonably tailored to avoid impinging Chapman's liberty no more than necessary, and reversed and remanded the case, reasoning that punitive infringement of fundamental rights, such as procreation, must only be done in an “exacting” way “to ensure that the condition does not limit the probationer’s liberty more than is necessary to achieve the goals of community control.”
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Justice Vote Breakdown
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Summary of Case Context & Holding
A man was convicted for failing to pay child support to the mothers of his 11 children and sentenced to community control. One of the conditions of community control imposed by the court was that the man “make all reasonable efforts to avoid impregnating a woman” during his sentence. Chapman, the Defendant, appealed, arguing that the condition was not reasonably related to a rehabilitative purpose and because it violated his constitutional right to procreate. On appeal, the Supreme Court noted that there is no question that procreating is a fundamental right and the condition limited that right. Thus, the crucial question, the court explained was how "to review conditions of sentencing that limit a fundamental right. The Supreme Court held that the procreation prohibition was not reasonably related to the goals of community control, nor was it reasonably tailored to avoid impinging Chapman's liberty no more than necessary, and reversed and remanded the case, reasoning that punitive infringement of fundamental rights, such as procreation, must only be done in an “exacting” way “to ensure that the condition does not limit the probationer’s liberty more than is necessary to achieve the goals of community control.”
Link to Opinion
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State v. Cheatham, 375 P.3d 66 (Ariz. 2016)
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Arizona | 2016 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2016
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPolice officers stopped Defendant’s vehicle for unlawful window tinting. Upon approaching the vehicle and speaking with Defendant, the officers noticed an odor of marijuana. The officers searched the car and found a small amount of marijuana. Defendant was arrested and charged with possession or use of marijuana. Defendant filed a motion to suppress arguing that, after passage of the Arizona Medical Marijuana Act, the odor of marijuana coming from a vehicle does not alone provide probable cause. The trial court denied the motion and then found Defendant guilty. The court of appeals affirmed. The Arizona Appellate Court in State v. Sisco, 359 P.3d 1 (Ariz. Ct. App. 2015), held that the odor of marijuana, alone, creates sufficient probable cause to search. Similarly, in the instant case, the Supreme Court affirmed, applying the rule from Sisco, holding that the odor of marijuana sufficed to establish probable cause, and therefore, the search was authorized by the automobile exception to the warrant requirement.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Police officers stopped Defendant’s vehicle for unlawful window tinting. Upon approaching the vehicle and speaking with Defendant, the officers noticed an odor of marijuana. The officers searched the car and found a small amount of marijuana. Defendant was arrested and charged with possession or use of marijuana. Defendant filed a motion to suppress arguing that, after passage of the Arizona Medical Marijuana Act, the odor of marijuana coming from a vehicle does not alone provide probable cause. The trial court denied the motion and then found Defendant guilty. The court of appeals affirmed. The Arizona Appellate Court in State v. Sisco, 359 P.3d 1 (Ariz. Ct. App. 2015), held that the odor of marijuana, alone, creates sufficient probable cause to search. Similarly, in the instant case, the Supreme Court affirmed, applying the rule from Sisco, holding that the odor of marijuana sufficed to establish probable cause, and therefore, the search was authorized by the automobile exception to the warrant requirement.
Link to Opinion
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State v. Chisum, 200 A.3d 1279 (N.J. 2019)
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New Jersey | 2019 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2019
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingWhile police officers were at a motel in response to a noise complaint, they ran warrant checks on everyone at the party, which took approximately 20 minutes, and the warrant check for Chisum, one of the ten people at the party, came back positive and he was placed under arrest. No summons was issued by the police. After handcuffing Chisum and escorting him into the hallway, Officer Harris conducted a search incident to arrest and patted Chisum down for weapons, revealing a handgun tucked into his waistband. The handgun was retrieved, and Chisum was secured in the hallway, and indicted for weapons offenses. The Defendant pled guilty in trial court to second-degree unlawful possession of a weapon. The trial court also found that the police were justified in conducting pat-down searches of the remaining occupants in the room for the officers’ safety. The Defendant pled guilty to one weapons charge; Woodard, another Defendant, pled guilty to one weapons offense and to a drug possession offense arising from an unrelated indictment. The Defendants appealed and the appellate court affirmed the trial court's holding. However, the Supreme Court disagreed, holding that the police officers unlawfully prolonged the investigative stop of Defendants, who were occupants in a motel room being investigated for a noise complaint, by ascertaining Defendants' identities, detaining them, and running warrant checks on them. The Supreme Court explained that "Once the renter of the motel room lowered the volume of the music and the police declined to issue summonses, the police no longer had any reasonable suspicion that would justify the continued detention of the room’s occupants" and because the detention and warrant checks were unlawful, the subsequent pat-down was improper.
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Justice Vote Breakdown
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Summary of Case Context & Holding
While police officers were at a motel in response to a noise complaint, they ran warrant checks on everyone at the party, which took approximately 20 minutes, and the warrant check for Chisum, one of the ten people at the party, came back positive and he was placed under arrest. No summons was issued by the police. After handcuffing Chisum and escorting him into the hallway, Officer Harris conducted a search incident to arrest and patted Chisum down for weapons, revealing a handgun tucked into his waistband. The handgun was retrieved, and Chisum was secured in the hallway, and indicted for weapons offenses. The Defendant pled guilty in trial court to second-degree unlawful possession of a weapon. The trial court also found that the police were justified in conducting pat-down searches of the remaining occupants in the room for the officers’ safety. The Defendant pled guilty to one weapons charge; Woodard, another Defendant, pled guilty to one weapons offense and to a drug possession offense arising from an unrelated indictment. The Defendants appealed and the appellate court affirmed the trial court's holding. However, the Supreme Court disagreed, holding that the police officers unlawfully prolonged the investigative stop of Defendants, who were occupants in a motel room being investigated for a noise complaint, by ascertaining Defendants' identities, detaining them, and running warrant checks on them. The Supreme Court explained that "Once the renter of the motel room lowered the volume of the music and the police declined to issue summonses, the police no longer had any reasonable suspicion that would justify the continued detention of the room’s occupants" and because the detention and warrant checks were unlawful, the subsequent pat-down was improper.
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State v. Clark, 999 N.E.2d 592 (Ohio 2013), rev'd and remanded, Ohio v. Clark, 576 U.S. 237 (2015)
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Ohio | 2013 | Criminal Justice, Juvenile Justice |
State:
Ohio
Year:
2013
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn response to questions made by teachers and social workers regarding bruises on a child's body, a child stated that his caretakers were responsible for the bruises on his body. While the child was deemed incompetent to testify, the statements made by the child were used against his caretakers at a trial in a case against the caretakers for child abuse. The Supreme Court held that statements elicited from a child by a teacher in the absence of an ongoing emergency and for the primary purpose of gathering information of past criminal conduct and identifying the alleged perpetrator of suspected child abuse are testimonial in nature, and, as a consequence, the defendant must be able to confront the child under the Sixth Amendment. The U.S. Supreme Court reversed this decision, unanimously deeming the statements non-testimonial.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In response to questions made by teachers and social workers regarding bruises on a child's body, a child stated that his caretakers were responsible for the bruises on his body. While the child was deemed incompetent to testify, the statements made by the child were used against his caretakers at a trial in a case against the caretakers for child abuse. The Supreme Court held that statements elicited from a child by a teacher in the absence of an ongoing emergency and for the primary purpose of gathering information of past criminal conduct and identifying the alleged perpetrator of suspected child abuse are testimonial in nature, and, as a consequence, the defendant must be able to confront the child under the Sixth Amendment. The U.S. Supreme Court reversed this decision, unanimously deeming the statements non-testimonial.
Link to Opinion
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State v. Clinton, 108 N.E.3d 1 (Ohio 2017)
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Ohio | 2017 | Criminal Justice, Death Penalty |
State:
Ohio
Year:
2017
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Defendant was charged with five counts of aggravated murder with death-penalty specifications and a jury found the Defendant guilty of all charges and specifications. On appeal, the Defendant raised 23 propositions of law, many of which were subject to plain error analysis because they were not raised by the Defendant's defense counsel at trial. The Defendant claimed that pre-trial publicity was prejudicial and pervasive enough to warrant a change of venue, and that a prospective juror who knew some of victims' family members should have been dismissed for cause; however, the Supreme Court rejected these claims finding that the trial court was conscious of pre-trial publicity in the case and took reasonable steps to ensure the jurors were not prejudiced, including excusing 24 potential jurors because they knew too much about the murders. The Defendant also claimed that his prior involuntary manslaughter conviction was inadmissible to establish his modus operandi with regard to either adult or child victims, but the Supreme Court said it was admissible with regard to both because the other acts evidence was related to and shared a common features.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Defendant was charged with five counts of aggravated murder with death-penalty specifications and a jury found the Defendant guilty of all charges and specifications. On appeal, the Defendant raised 23 propositions of law, many of which were subject to plain error analysis because they were not raised by the Defendant's defense counsel at trial. The Defendant claimed that pre-trial publicity was prejudicial and pervasive enough to warrant a change of venue, and that a prospective juror who knew some of victims' family members should have been dismissed for cause; however, the Supreme Court rejected these claims finding that the trial court was conscious of pre-trial publicity in the case and took reasonable steps to ensure the jurors were not prejudiced, including excusing 24 potential jurors because they knew too much about the murders. The Defendant also claimed that his prior involuntary manslaughter conviction was inadmissible to establish his modus operandi with regard to either adult or child victims, but the Supreme Court said it was admissible with regard to both because the other acts evidence was related to and shared a common features.
Link to Opinion
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State v. Cohen, 296 A.3d 480 (N.J. 2023)
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New Jersey | 2023 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2023
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingA confidential informant (CI) emailed police telling them to "be on the lookout" for Defendant who would be traveling to pick up firearms to sell. Police noticed one of the cars described in the email driving on the highway and pulled it over for traffic violations. The officer smelled a "strong odor of raw marijuana" in the car and saw greenish-brown vegetation on the driver's beard and shirt. The officer removed Defendant from the car and searched the passenger compartment where he discovered a shell casing but no marijuana. The officer had not applied for a search warrant based on the information from the CI, but proceeded to search under the vehicle's hood and engine compartment where he found a rifle and a revolver as well as a duffle bag of bullets but no marijuana. Defendant moved to suppress the evidence seized during the car search. The trial court held there was probable cause to search the whole vehicle based on the marijuana smell and the appellate court confirmed. The issue before the New Jersey Supreme Court was whether the odor of marijuana in a vehicle authorizes a search of the engine compartment and trunk under the automobile exception to the warrant requirement. The Court held that, although the initial warrantless search was valid under the automobile exception, expanding the search to the engine compartment and trunk went beyond the scope of the automobile exception because police did not have probable cause to expand the search. Although the trooper smelled marijuana in the passenger compartment of the car, his initial search yielded no results and provided no justification “to extend the zone of the . . . search further than the persons of the occupants or the interior of the car.” State v. Patino, 414 A.2d 1327, 1334 (N.J. 1980). As a result, the Court held that the seized evidence should be suppressed.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A confidential informant (CI) emailed police telling them to "be on the lookout" for Defendant who would be traveling to pick up firearms to sell. Police noticed one of the cars described in the email driving on the highway and pulled it over for traffic violations. The officer smelled a "strong odor of raw marijuana" in the car and saw greenish-brown vegetation on the driver's beard and shirt. The officer removed Defendant from the car and searched the passenger compartment where he discovered a shell casing but no marijuana. The officer had not applied for a search warrant based on the information from the CI, but proceeded to search under the vehicle's hood and engine compartment where he found a rifle and a revolver as well as a duffle bag of bullets but no marijuana. Defendant moved to suppress the evidence seized during the car search. The trial court held there was probable cause to search the whole vehicle based on the marijuana smell and the appellate court confirmed. The issue before the New Jersey Supreme Court was whether the odor of marijuana in a vehicle authorizes a search of the engine compartment and trunk under the automobile exception to the warrant requirement. The Court held that, although the initial warrantless search was valid under the automobile exception, expanding the search to the engine compartment and trunk went beyond the scope of the automobile exception because police did not have probable cause to expand the search. Although the trooper smelled marijuana in the passenger compartment of the car, his initial search yielded no results and provided no justification “to extend the zone of the . . . search further than the persons of the occupants or the interior of the car.” State v. Patino, 414 A.2d 1327, 1334 (N.J. 1980). As a result, the Court held that the seized evidence should be suppressed.
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State v. Coleman, 832 S.E.2d 389 (Ga. 2019)
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Georgia | 2019 | Criminal Justice, Juvenile Justice |
State:
Georgia
Year:
2019
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 2016, Defendant, who was 16 at the time of his arrest, was indicted for felony murder and burglary. Two years later in 2018, Defendant and his Co-Defendants were re-indicted on the same charges. Defendant filed a motion to transfer his case to juvenile court, arguing that, because the 2018 indictment was returned outside the 180-day time limit set by O.C.G.A. § 17-7-50.1, the superior court no longer had jurisdiction. The Supreme Court held that the superior court erred in granting a juvenile's motion to transfer his murder case to juvenile court under O.C.G.A. § 17-7-50.1 because the juvenile had been released on bond and the 180-day period only ran during the time the juvenile had been detained. O.C.G.A. § 17-7-50.1 entitles a child who "is detained" on criminal charges within the jurisdiction of the superior court to have those criminal charges presented to a grand jury within 180 days of the date of detention. "Detained" means to keep in custody or confine, so because the juvenile was released on bond, he was no longer detained within the meaning of the statute. The Supreme Court held that the 180-day time limitation in O.C.G.A. § 17-7-50.1 does not apply to a juvenile who is released and remains on bond prior to the running of 180 days. The Supreme Court's determination overruled Edwards v. State, 748 S.E.2d 501 (Ga. Ct. App. 2013), and further concluded that the trial court erred in transferring Defendant's case to the juvenile court.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 2016, Defendant, who was 16 at the time of his arrest, was indicted for felony murder and burglary. Two years later in 2018, Defendant and his Co-Defendants were re-indicted on the same charges. Defendant filed a motion to transfer his case to juvenile court, arguing that, because the 2018 indictment was returned outside the 180-day time limit set by O.C.G.A. § 17-7-50.1, the superior court no longer had jurisdiction. The Supreme Court held that the superior court erred in granting a juvenile's motion to transfer his murder case to juvenile court under O.C.G.A. § 17-7-50.1 because the juvenile had been released on bond and the 180-day period only ran during the time the juvenile had been detained. O.C.G.A. § 17-7-50.1 entitles a child who "is detained" on criminal charges within the jurisdiction of the superior court to have those criminal charges presented to a grand jury within 180 days of the date of detention. "Detained" means to keep in custody or confine, so because the juvenile was released on bond, he was no longer detained within the meaning of the statute. The Supreme Court held that the 180-day time limitation in O.C.G.A. § 17-7-50.1 does not apply to a juvenile who is released and remains on bond prior to the running of 180 days. The Supreme Court's determination overruled Edwards v. State, 748 S.E.2d 501 (Ga. Ct. App. 2013), and further concluded that the trial court erred in transferring Defendant's case to the juvenile court.
Link to Opinion
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State v. Coleman, 832 S.E.2d 389 (Ga. 2019)
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Georgia | 2019 | Criminal Justice |
State:
Georgia
Year:
2019
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was indicted for felony murder and burglary in 2016 when Defendant was 16 years old, granted bond in 2016, and re-indicted for the same charges in 2018. Defendant moved to transfer his case to juvenile court. The trial court granted Defendant’s motion to transfer, but the State appealed, arguing that the trial court granted the motion in error. Upon review, the Supreme Court held that: (1) a child must be detained in order for the 180-day statutory time period (codified at O.C.G.A. § 17-7-50.1) within which the State is required to obtain an indictment of a juvenile charged with a crime within the jurisdiction of the superior court to run, overruling Edwards v. State, 748 S.E.2d 501 (Ga. Ct. App. 2013) (Edwards, 748 S.E.2d at 503 held that “nothing in the statute mandates that the defendant continue to be detained for the entire 180-day period.”); and (2) the statutory 180-day time limitation for obtaining an indictment of a juvenile charged with a crime within the jurisdiction of the superior court did not apply to a juvenile who was released and remained on bond prior to the running of 180 days. The Supreme Court reversed and concluded that the trial court erred in transferring the Defendant's case to the juvenile court.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was indicted for felony murder and burglary in 2016 when Defendant was 16 years old, granted bond in 2016, and re-indicted for the same charges in 2018. Defendant moved to transfer his case to juvenile court. The trial court granted Defendant’s motion to transfer, but the State appealed, arguing that the trial court granted the motion in error. Upon review, the Supreme Court held that: (1) a child must be detained in order for the 180-day statutory time period (codified at O.C.G.A. § 17-7-50.1) within which the State is required to obtain an indictment of a juvenile charged with a crime within the jurisdiction of the superior court to run, overruling Edwards v. State, 748 S.E.2d 501 (Ga. Ct. App. 2013) (Edwards, 748 S.E.2d at 503 held that “nothing in the statute mandates that the defendant continue to be detained for the entire 180-day period.”); and (2) the statutory 180-day time limitation for obtaining an indictment of a juvenile charged with a crime within the jurisdiction of the superior court did not apply to a juvenile who was released and remained on bond prior to the running of 180 days. The Supreme Court reversed and concluded that the trial court erred in transferring the Defendant's case to the juvenile court.
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State v. Conley, 839 S.E.2d 805 (N.C. 2020)
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North Carolina | 2020 | Education, Gun Control in Schools/School Safety, Criminal Justice |
State:
North Carolina
Year:
2020
Topics:
Education, Gun Control in Schools/School Safety, Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant fired shots at multiple people on school property. Defendant argued that the multiple firearms he had did not justify more than one conviction on the count of "possession of firearms on school property." The statute at issue here, N.C. Gen. Stat. § 14-269.2(b), states that it is a felony for "any person knowingly to possess or carry, whether openly or concealed, any gun, rifle, pistol, or other firearm of any kind on educational property or to a curricular or extracurricular activity sponsored by a school." Looking closely at the statute's language, the Supreme Court reasoned that the word "any" followed by singular nouns is ambiguous and could be referring to one or multiple items. The Supreme Court applied the Rule of Lenity because of the statute's ambiguity, meaning that they interpreted the statute in the light most favorable to the defendant. The Supreme Court used this principle to arrive at the conclusion that the statute only allows for one violation. The Supreme Court held that a person can only receive a single conviction under the statute for possession of firearms on school property.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant fired shots at multiple people on school property. Defendant argued that the multiple firearms he had did not justify more than one conviction on the count of "possession of firearms on school property." The statute at issue here, N.C. Gen. Stat. § 14-269.2(b), states that it is a felony for "any person knowingly to possess or carry, whether openly or concealed, any gun, rifle, pistol, or other firearm of any kind on educational property or to a curricular or extracurricular activity sponsored by a school." Looking closely at the statute's language, the Supreme Court reasoned that the word "any" followed by singular nouns is ambiguous and could be referring to one or multiple items. The Supreme Court applied the Rule of Lenity because of the statute's ambiguity, meaning that they interpreted the statute in the light most favorable to the defendant. The Supreme Court used this principle to arrive at the conclusion that the statute only allows for one violation. The Supreme Court held that a person can only receive a single conviction under the statute for possession of firearms on school property.
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State v. Conner, 873 S.E.2d 339 (N.C. 2022)
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North Carolina | 2022 | Criminal Justice, Juvenile Justice |
State:
North Carolina
Year:
2022
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAs a matter of first impression, the Supreme Court held that the Eighth Amendment and North Carolina Constitution require that redeemable juvenile homicide offenders who receive consecutive sentences have the opportunity to seek parole after serving 40 years. An offender is redeemable unless their crimes reflect "irreparable corruption." In this case, Defendant was convicted of rape and murder at age 15 and received a sentence that did not allow him to apply for release on parole until he was in his sixties. The U.S. Supreme Court, in Miller v. Alabama, 567 U.S. 460 (2012), treated juvenile life sentences as analogous to capital punishment and found that "appropriate occasions for sentencing juveniles to this harshest possible penalty will be uncommon." The U.S. Supreme Court reasoned that juveniles have diminished capacity and greater prospects for reform which makes them constitutionally different than adults. The Supreme Court relied on reasoning from Miller that requires redeemable juvenile defendants to have an opportunity to demonstrate their readiness for parole after some term of incarceration. The Supreme Court found that, as a result, a maximum duration for incarceration before the possibility of parole should be set for redeemable juvenile offenders. Because the Supreme Court placed this maximum at 40 years, it also found that sentencing for the Defendant in this case should retain the opportunity to seek parole.
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Justice Vote Breakdown
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Summary of Case Context & Holding
As a matter of first impression, the Supreme Court held that the Eighth Amendment and North Carolina Constitution require that redeemable juvenile homicide offenders who receive consecutive sentences have the opportunity to seek parole after serving 40 years. An offender is redeemable unless their crimes reflect "irreparable corruption." In this case, Defendant was convicted of rape and murder at age 15 and received a sentence that did not allow him to apply for release on parole until he was in his sixties. The U.S. Supreme Court, in Miller v. Alabama, 567 U.S. 460 (2012), treated juvenile life sentences as analogous to capital punishment and found that "appropriate occasions for sentencing juveniles to this harshest possible penalty will be uncommon." The U.S. Supreme Court reasoned that juveniles have diminished capacity and greater prospects for reform which makes them constitutionally different than adults. The Supreme Court relied on reasoning from Miller that requires redeemable juvenile defendants to have an opportunity to demonstrate their readiness for parole after some term of incarceration. The Supreme Court found that, as a result, a maximum duration for incarceration before the possibility of parole should be set for redeemable juvenile offenders. Because the Supreme Court placed this maximum at 40 years, it also found that sentencing for the Defendant in this case should retain the opportunity to seek parole.
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State v. Cooper, 929 N.W.2d 192 (Wis. 2019)
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Wisconsin | 2019 | Criminal Justice, Access to Justice |
State:
Wisconsin
Year:
2019
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant's counsel was disciplined for misconduct, including not providing discovery documents to the Defendant, failing to notify the Defendant that his license had been suspended, not discussing his preparation for trial with the Defendant, and not addressing issues raised in letters written by the Defendant. Even though the defense attorney engaged in misconduct in handling the Defendant's case, the Defendant still could not establish that he had received ineffective assistance of counsel sufficient to get a new trial because he failed to show how that he was prejudiced by his counsel's performance within the meaning of Strickland v. Washington, 466 U.S. 668 (1984). Strickland held that ineffective assistance of counsel requires the both deficient performance and a reasonable probability that a competent attorney would have led to a different outcome. The Defendant's motion to withdraw his guilty plea was denied and his conviction was affirmed.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant's counsel was disciplined for misconduct, including not providing discovery documents to the Defendant, failing to notify the Defendant that his license had been suspended, not discussing his preparation for trial with the Defendant, and not addressing issues raised in letters written by the Defendant. Even though the defense attorney engaged in misconduct in handling the Defendant's case, the Defendant still could not establish that he had received ineffective assistance of counsel sufficient to get a new trial because he failed to show how that he was prejudiced by his counsel's performance within the meaning of Strickland v. Washington, 466 U.S. 668 (1984). Strickland held that ineffective assistance of counsel requires the both deficient performance and a reasonable probability that a competent attorney would have led to a different outcome. The Defendant's motion to withdraw his guilty plea was denied and his conviction was affirmed.
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State v. Counts, 776 S.E.2d 59 (S.C. 2015)
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South Carolina | 2015 | Civil Rights, Criminal Justice |
State:
South Carolina
Year:
2015
Topics:
Civil Rights, Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingCounts was convicted of possession with intent to distribute marijuana, his third offense. During his trial, he moved to suppress the drugs and a weapon recovered from his home on the grounds that the police's search of his home violated the Fourth Amendment and the South Carolina Constitution. He argued that the officer's use of the "knock and talk" technique, where officers approach a residence and explain an allegation to someone who has been accused of wrongdoing, is violative of the Fourth Amendment (and the parallel provision in the South Carolina Constitution) when officers who do not have reasonable suspicion or probable cause use the technique to circumvent the warrant requirement. The Supreme Court affirmed the court of appeal's affirmation of Count's conviction. The Supreme Court held that pursuant to the U.S. Supreme Court's Florida v. Jardines, 569 U.S. 1 (2013), the search was not violative of the Fourth Amendment (and parallel provision in the South Carolina Constitution) as once Counts opened the door during the "knock and talk," exigent circumstances arose when the officers saw that he had a weapon, meaning they were justified to conduct a protective sweep and observed in plain view drugs and narcotics material. However, as the South Carolina Constitution affords its citizens an express right to privacy, the Court further held that law enforcement must have a reasonable suspicion of illegal activity before approaching the targeted residence and conducting a "knock and talk" investigative technique. The Court determined the officers had reasonable suspicion in performing the "knock and talk."
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Justice Vote Breakdown
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Summary of Case Context & Holding
Counts was convicted of possession with intent to distribute marijuana, his third offense. During his trial, he moved to suppress the drugs and a weapon recovered from his home on the grounds that the police's search of his home violated the Fourth Amendment and the South Carolina Constitution. He argued that the officer's use of the "knock and talk" technique, where officers approach a residence and explain an allegation to someone who has been accused of wrongdoing, is violative of the Fourth Amendment (and the parallel provision in the South Carolina Constitution) when officers who do not have reasonable suspicion or probable cause use the technique to circumvent the warrant requirement. The Supreme Court affirmed the court of appeal's affirmation of Count's conviction. The Supreme Court held that pursuant to the U.S. Supreme Court's Florida v. Jardines, 569 U.S. 1 (2013), the search was not violative of the Fourth Amendment (and parallel provision in the South Carolina Constitution) as once Counts opened the door during the "knock and talk," exigent circumstances arose when the officers saw that he had a weapon, meaning they were justified to conduct a protective sweep and observed in plain view drugs and narcotics material. However, as the South Carolina Constitution affords its citizens an express right to privacy, the Court further held that law enforcement must have a reasonable suspicion of illegal activity before approaching the targeted residence and conducting a "knock and talk" investigative technique. The Court determined the officers had reasonable suspicion in performing the "knock and talk."
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State v. Courtney, 233 A.3d 454 (N.J. 2020)
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New Jersey | 2020 | Criminal Justice |
State:
New Jersey
Year:
2020
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant appealed from the judgment of the Appellate Division affirming his sentence for possession of heroin with the intent to distribute. Due to his criminal history, Defendant faced a mandatory extended-term sentence and minimum period of parole ineligibility if convicted. During plea negotiations, the State advised Defendant and the court that Defendant qualified for an extended term. However, the State agreed to defense counsel's proposed sentence. Defendant entered a guilty plea under the terms of the plea agreement and the trial court imposed the agreed-upon sentence. However, despite acknowledging the plea agreement, defense counsel requested a reduced sentence. The trial court denied the request and the Appellate Division affirmed, rejecting Defendant's contention that the trial court had discretion to lower the sentence because the state failed to file a formal application for an extended term. On appeal, the Court affirmed the judgment of the Appellate Division. The Court ruled that, when seeking the plea agreement at issue, the State was not required to file an application where the State had agreed not to request a mandatory extended term sentence. The Court held that filing an application only to withdraw it at sentencing would be a waste of judicial resources. The Court further noted that Defendant was given notice that he was eligible for an extended-term sentence and that the State was seeking to negotiate a plea agreement. The Court also noted that Defendant did not object to the State's proffer that he was extended-term eligible. The Court suggested revisions to plea bargain procedures and the plea form to resolve disputes over whether a defendant was extended-term eligible.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant appealed from the judgment of the Appellate Division affirming his sentence for possession of heroin with the intent to distribute. Due to his criminal history, Defendant faced a mandatory extended-term sentence and minimum period of parole ineligibility if convicted. During plea negotiations, the State advised Defendant and the court that Defendant qualified for an extended term. However, the State agreed to defense counsel's proposed sentence. Defendant entered a guilty plea under the terms of the plea agreement and the trial court imposed the agreed-upon sentence. However, despite acknowledging the plea agreement, defense counsel requested a reduced sentence. The trial court denied the request and the Appellate Division affirmed, rejecting Defendant's contention that the trial court had discretion to lower the sentence because the state failed to file a formal application for an extended term. On appeal, the Court affirmed the judgment of the Appellate Division. The Court ruled that, when seeking the plea agreement at issue, the State was not required to file an application where the State had agreed not to request a mandatory extended term sentence. The Court held that filing an application only to withdraw it at sentencing would be a waste of judicial resources. The Court further noted that Defendant was given notice that he was eligible for an extended-term sentence and that the State was seeking to negotiate a plea agreement. The Court also noted that Defendant did not object to the State's proffer that he was extended-term eligible. The Court suggested revisions to plea bargain procedures and the plea form to resolve disputes over whether a defendant was extended-term eligible.
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State v. Courtney, 831 S.E.2d 260 (N.C. 2019)
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North Carolina | 2019 | Criminal Justice |
State:
North Carolina
Year:
2019
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court held that double jeopardy would be violated if Defendant were subject to a second trial when the State voluntarily dismissed the Defendant's murder charge. Defendant's original trial ended in a hung jury and was declared a mistrial. At that time, the State dismissed the charge. Years later when new evidence emerged, the State sought to re-try the Defendant. The Supreme Court held that the second prosecution was barred by double jeopardy. The Supreme Court reasoned that the original jeopardy of the Defendant's trial was concluded by the voluntary dismissal of the case by the State, not the mistrial alone did not conclude the original jeopardy. In essence, the dismissal was found to be tantamount to acquittal.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court held that double jeopardy would be violated if Defendant were subject to a second trial when the State voluntarily dismissed the Defendant's murder charge. Defendant's original trial ended in a hung jury and was declared a mistrial. At that time, the State dismissed the charge. Years later when new evidence emerged, the State sought to re-try the Defendant. The Supreme Court held that the second prosecution was barred by double jeopardy. The Supreme Court reasoned that the original jeopardy of the Defendant's trial was concluded by the voluntary dismissal of the case by the State, not the mistrial alone did not conclude the original jeopardy. In essence, the dismissal was found to be tantamount to acquittal.
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State v. Cox, 884 N.W.2d 400 (Minn. 2016)
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Minnesota | 2016 | Criminal Justice, Police Misconduct and Bias |
State:
Minnesota
Year:
2016
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant was found guilty by jury of first-degree premeditated murder, two counts of first-degree intentional felony murder (burglary and aggravated robbery), and first-degree aggravated robbery. Prior to trial, the district court denied Appellant’s motion to suppress a statement he made to the police. The statement occurred when the Appellant was brought into the police station upon his arrest and interviewed by the police. During the interview, Appellant asked the investigators about the status of the police investigation into the cause of his own brother's death (who died via gunshot wound to the head). Per the recording of the interview, the Appellant initiated a negotiation with the investigators wherein he would confess if the investigators agreed to "look into" the matter of his brother's death. Ultimately, the district court sentenced Appellant to life without the possibility of release for the first-degree premeditated murder conviction and a concurrent 81-month sentence for the first-degree aggravated robbery conviction. Appellant appealed, arguing that the district court committed reversible error by denying his motion to suppress his confession, which was unlawful because (1) police promised that in exchange for his confession they would look into his brother's death; (2) police assured him they could influence the county attorney; and (3) police told him that small town county court would be more lenient if he gave a full confession (in other words, his statement was not voluntary). The Supreme Court held that (1) Appellant's confession was not rendered involuntarily when police promised they would look into his brother’s death in exchange for a statement; (2) law enforcement officers’ statements suggesting full confession would be viewed favorably by prosecutor were not coercive; and (3) officers’ statements indicating that juries in county were more likely to be lenient if presented with full confession were not coercive. As a result, the Supreme Court affirmed the lower court's decision.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant was found guilty by jury of first-degree premeditated murder, two counts of first-degree intentional felony murder (burglary and aggravated robbery), and first-degree aggravated robbery. Prior to trial, the district court denied Appellant’s motion to suppress a statement he made to the police. The statement occurred when the Appellant was brought into the police station upon his arrest and interviewed by the police. During the interview, Appellant asked the investigators about the status of the police investigation into the cause of his own brother's death (who died via gunshot wound to the head). Per the recording of the interview, the Appellant initiated a negotiation with the investigators wherein he would confess if the investigators agreed to "look into" the matter of his brother's death. Ultimately, the district court sentenced Appellant to life without the possibility of release for the first-degree premeditated murder conviction and a concurrent 81-month sentence for the first-degree aggravated robbery conviction. Appellant appealed, arguing that the district court committed reversible error by denying his motion to suppress his confession, which was unlawful because (1) police promised that in exchange for his confession they would look into his brother's death; (2) police assured him they could influence the county attorney; and (3) police told him that small town county court would be more lenient if he gave a full confession (in other words, his statement was not voluntary). The Supreme Court held that (1) Appellant's confession was not rendered involuntarily when police promised they would look into his brother’s death in exchange for a statement; (2) law enforcement officers’ statements suggesting full confession would be viewed favorably by prosecutor were not coercive; and (3) officers’ statements indicating that juries in county were more likely to be lenient if presented with full confession were not coercive. As a result, the Supreme Court affirmed the lower court's decision.
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State v. Crider, 328 P.3d 612 (Mont. 2014)
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Montana | 2014 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2014
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of sexual intercourse without consent, misdemeanor Partner of Family Member Assault. At trial, evidence was admitted which showed the abusive and sexual history of the Defendant and the victim. The State used this evidence to show Defendant’s “motive to exert power and control over his victim, and to use force to do so.” Defendant, on the other hand, used this evidence to show that the couple frequently engaged in rough sex and that, if he exceeded the scope of consent in the particular instance in question, he had done so accidentally. On appeal, Defendant argued that (i) the district court abused its discretion by admitting evidence that Defendant had previously assaulted and harassed the victim; and (ii) Defendant received ineffective assistance of counsel when counsel failed to object to the State’s use of the previous bad acts. On appeal, the State argued that Defendant had not preserved his first argument for appeal. The Court held that Defendant’s motion in limine did preserve the evidentiary objections for appeal because it referenced specific inadmissible evidence of bad acts, including particular dates and allegations, and provided a legal theory for excluding the evidence. The Court reasoned that the district court did not abuse its discretion in determining that Defendant's prior acts were admissible under Mont. R. Evid. 404(b) to show motive or absence of mistake or accident because they were probative of Defendant's motive to control or harass the victim and the evidence was relevant, not only to Defendant's motive as to the sex acts alleged, but also to his motive to commit witness tampering. The Court held that Defendant’s counsel was not ineffective because counsel’s failure to object to the State’s use of the prior acts evidence fell within counsel’s tactical discretion. The Court also indicated that no grounds for an objection existed with respect to the State’s use of the prior acts evidence. At trial, after he lost the motion in limine to suppress the evidence of prior acts, Defendant’s own trial strategy was adjusted to use such evidence to his advantage by using the evidence to show a history of rough sex. With this in mind, defense counsel’s decision not to object to the testimony was reasonable and in line with Defendant’s trial strategy.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of sexual intercourse without consent, misdemeanor Partner of Family Member Assault. At trial, evidence was admitted which showed the abusive and sexual history of the Defendant and the victim. The State used this evidence to show Defendant’s “motive to exert power and control over his victim, and to use force to do so.” Defendant, on the other hand, used this evidence to show that the couple frequently engaged in rough sex and that, if he exceeded the scope of consent in the particular instance in question, he had done so accidentally. On appeal, Defendant argued that (i) the district court abused its discretion by admitting evidence that Defendant had previously assaulted and harassed the victim; and (ii) Defendant received ineffective assistance of counsel when counsel failed to object to the State’s use of the previous bad acts. On appeal, the State argued that Defendant had not preserved his first argument for appeal. The Court held that Defendant’s motion in limine did preserve the evidentiary objections for appeal because it referenced specific inadmissible evidence of bad acts, including particular dates and allegations, and provided a legal theory for excluding the evidence. The Court reasoned that the district court did not abuse its discretion in determining that Defendant's prior acts were admissible under Mont. R. Evid. 404(b) to show motive or absence of mistake or accident because they were probative of Defendant's motive to control or harass the victim and the evidence was relevant, not only to Defendant's motive as to the sex acts alleged, but also to his motive to commit witness tampering. The Court held that Defendant’s counsel was not ineffective because counsel’s failure to object to the State’s use of the prior acts evidence fell within counsel’s tactical discretion. The Court also indicated that no grounds for an objection existed with respect to the State’s use of the prior acts evidence. At trial, after he lost the motion in limine to suppress the evidence of prior acts, Defendant’s own trial strategy was adjusted to use such evidence to his advantage by using the evidence to show a history of rough sex. With this in mind, defense counsel’s decision not to object to the testimony was reasonable and in line with Defendant’s trial strategy.
Link to Opinion
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State v. Cruz, 487 P.3d 981 (Ariz. 2021)
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Arizona | 2021 | Criminal Justice, Death Penalty |
State:
Arizona
Year:
2021
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of first-degree murder and sentenced to death. After the United States Supreme Court decided Lynch v. Arizona, 578 U.S. 613 (2016) (Lynch II), which held that defendants in capital cases have a due process right to inform the jury of parole ineligibility, Defendant filed a post-conviction relief (PCR) petition. The PCR court denied the petition, concluding that Lynch II did not amount to a significant change in the law permitting relief. The Arizona Supreme Court affirmed, holding that Lynch II was not a significant change in the law because it did not change any interpretation of federal constitutional law and no Supreme Court precedent was overruled or modified. Therefore, Defendant was not entitled to relief.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of first-degree murder and sentenced to death. After the United States Supreme Court decided Lynch v. Arizona, 578 U.S. 613 (2016) (Lynch II), which held that defendants in capital cases have a due process right to inform the jury of parole ineligibility, Defendant filed a post-conviction relief (PCR) petition. The PCR court denied the petition, concluding that Lynch II did not amount to a significant change in the law permitting relief. The Arizona Supreme Court affirmed, holding that Lynch II was not a significant change in the law because it did not change any interpretation of federal constitutional law and no Supreme Court precedent was overruled or modified. Therefore, Defendant was not entitled to relief.
Link to Opinion
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State v. Cuff, 217 A.3d 129 (N.J. 2019)
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New Jersey | 2019 | Criminal Justice, Access to Justice |
State:
New Jersey
Year:
2019
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingCuff, the Defendant, was convicted in trial court of numerous offenses based on his participation in multiple residential burglaries in which he and his cohorts bound the victims. Cuff also stole a car in the course of fleeing a car stop. The trial court instructed the jury on first- and second-degree kidnapping, the latter of which is appropriate when the defendant releases the victim unharmed and in a safe place. The trial court did not include the second-degree crime on the verdict sheet and trial counsel did not object. The Appellate Division affirmed Defendant’s conviction and sentence with respect to all but the conviction of second-degree conspiracy to commit "robbery and/or kidnapping" and adjusted the sentence accordingly, finding that the trial court's instruction improperly combined two distinct conspiracy charges and that the jury may not have unanimously convicted Defendant for a single offense. The Supreme Court reversed as to the trial court's imposition of consecutive sentences, finding that the trial court should resentence the Defendant after considering whether certain offenses committed within the "same criminal episode" warranted concurrent rather than consecutive sentences, as well as whether the decision to make the sentences consecutive rather than concurrent made the aggregate sentence imposed on Defendant an abuse of discretion. The Supreme Court clarified that the trial court did not abuse its discretion in ordering that sentences imposed for multiple offenses committed during one criminal episode run consecutive to sentences imposed for offenses committed during different criminal episodes.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Cuff, the Defendant, was convicted in trial court of numerous offenses based on his participation in multiple residential burglaries in which he and his cohorts bound the victims. Cuff also stole a car in the course of fleeing a car stop. The trial court instructed the jury on first- and second-degree kidnapping, the latter of which is appropriate when the defendant releases the victim unharmed and in a safe place. The trial court did not include the second-degree crime on the verdict sheet and trial counsel did not object. The Appellate Division affirmed Defendant’s conviction and sentence with respect to all but the conviction of second-degree conspiracy to commit "robbery and/or kidnapping" and adjusted the sentence accordingly, finding that the trial court's instruction improperly combined two distinct conspiracy charges and that the jury may not have unanimously convicted Defendant for a single offense. The Supreme Court reversed as to the trial court's imposition of consecutive sentences, finding that the trial court should resentence the Defendant after considering whether certain offenses committed within the "same criminal episode" warranted concurrent rather than consecutive sentences, as well as whether the decision to make the sentences consecutive rather than concurrent made the aggregate sentence imposed on Defendant an abuse of discretion. The Supreme Court clarified that the trial court did not abuse its discretion in ordering that sentences imposed for multiple offenses committed during one criminal episode run consecutive to sentences imposed for offenses committed during different criminal episodes.
Link to Opinion
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State v. Curtis, 905 N.W.2d 609 (Minn. 2018)
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Minnesota | 2018 | Criminal Justice, Access to Justice |
State:
Minnesota
Year:
2018
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant was convicted of first-degree premeditated murder for a shooting death. One member of the jury who had previously seen the list of witnesses to the trial during pre-trial procedures, realized after the trial began that she knew one of the trial witnesses, and immediately brought this fact to the Court's attention. Appellant asked that the juror be removed, and the district court declined to remove the juror. Appellant argued that the district court abused its discretion when it declined to remove the juror, on the grounds that such juror had lied repeatedly on the stand in order to get a seat on the jury. The Supreme Court held that there was no evidence that the juror lied, but rather that she made an innocent mistake and came forward as soon as she realized her error. The Supreme Court determined that these facts do not reflect any actual bias, and affirmed on those grounds.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant was convicted of first-degree premeditated murder for a shooting death. One member of the jury who had previously seen the list of witnesses to the trial during pre-trial procedures, realized after the trial began that she knew one of the trial witnesses, and immediately brought this fact to the Court's attention. Appellant asked that the juror be removed, and the district court declined to remove the juror. Appellant argued that the district court abused its discretion when it declined to remove the juror, on the grounds that such juror had lied repeatedly on the stand in order to get a seat on the jury. The Supreme Court held that there was no evidence that the juror lied, but rather that she made an innocent mistake and came forward as soon as she realized her error. The Supreme Court determined that these facts do not reflect any actual bias, and affirmed on those grounds.
Link to Opinion
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State v. Dalton, 914 N.W.2d 120 (Wis. 2018)
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Wisconsin | 2018 | Criminal Justice, Police Misconduct and Bias |
State:
Wisconsin
Year:
2018
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of operating a vehicle while intoxicated (OWI). Defendant filed a motion to vacate his no-contest plea based on ineffective assistance of counsel, arguing that his counsel should have moved to suppress the results of a warrantless blood draw. The Supreme Court held that the warrantless blood draw was justified by exigent circumstances, namely, that unless the blood draw were taken quickly it would not shed light on the Defendant's blood alcohol content at the time of his arrest. Therefore, even if Defendant's counsel had filed a motion to suppress, it would have been denied. The Supreme Court also held that an enhanced sentence based on Defendant’s refusal to submit to the blood draw was impermissible because the enhanced sentence would be a punishment for exercising the constitutional right to refuse to submit a blood sample.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of operating a vehicle while intoxicated (OWI). Defendant filed a motion to vacate his no-contest plea based on ineffective assistance of counsel, arguing that his counsel should have moved to suppress the results of a warrantless blood draw. The Supreme Court held that the warrantless blood draw was justified by exigent circumstances, namely, that unless the blood draw were taken quickly it would not shed light on the Defendant's blood alcohol content at the time of his arrest. Therefore, even if Defendant's counsel had filed a motion to suppress, it would have been denied. The Supreme Court also held that an enhanced sentence based on Defendant’s refusal to submit to the blood draw was impermissible because the enhanced sentence would be a punishment for exercising the constitutional right to refuse to submit a blood sample.
Link to Opinion
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State v. Davis, 371 P.3d 979 (Mont. 2016)
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Montana | 2016 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2016
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was arrested on suspicion of DUI. Two days following Defendant's arrest, the Board of Commissioners of Park County passed a resolution which changed the Park County Justice Court from a non-record court into a court of record. Defendant was arraigned in the Park County Justice Court, before the Honorable Linda Budeski, who is not an attorney licensed to practice law in Montana. The two issues addressed by the Court were whether Defendant's trial before a non-lawyer justice of the peace (i) violated his constitutionally-guaranteed right to due process of law; or (ii) deprived him of his constitutionally-guaranteed right to effective assistance of counsel. With respect to the first issue, the Court reasoned that Montana's court structure and the appeals system ensures that a defendant's case in a justice court of record includes the opportunity for a complete and meaningful de novo review of legal issues by law-trained judges, and based on that, the Court found no basis upon which to conclude that properly trained non-lawyer judges are incapable of making factual determinations or exercising discretion appropriately, or that a license to practice law would improve their ability to do so. As for the second issue, the Court concluded that requiring Defendant to proceed to trial before a non-lawyer justice of the peace did not violate his constitutionally-guaranteed right to effective assistance of counsel because while fairness requires that a defendant has the right to be represented by legal counsel in order to ensure protection of the accused's rights, it does not follow that the trial in such a case must be presided over by a lawyer.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was arrested on suspicion of DUI. Two days following Defendant's arrest, the Board of Commissioners of Park County passed a resolution which changed the Park County Justice Court from a non-record court into a court of record. Defendant was arraigned in the Park County Justice Court, before the Honorable Linda Budeski, who is not an attorney licensed to practice law in Montana. The two issues addressed by the Court were whether Defendant's trial before a non-lawyer justice of the peace (i) violated his constitutionally-guaranteed right to due process of law; or (ii) deprived him of his constitutionally-guaranteed right to effective assistance of counsel. With respect to the first issue, the Court reasoned that Montana's court structure and the appeals system ensures that a defendant's case in a justice court of record includes the opportunity for a complete and meaningful de novo review of legal issues by law-trained judges, and based on that, the Court found no basis upon which to conclude that properly trained non-lawyer judges are incapable of making factual determinations or exercising discretion appropriately, or that a license to practice law would improve their ability to do so. As for the second issue, the Court concluded that requiring Defendant to proceed to trial before a non-lawyer justice of the peace did not violate his constitutionally-guaranteed right to effective assistance of counsel because while fairness requires that a defendant has the right to be represented by legal counsel in order to ensure protection of the accused's rights, it does not follow that the trial in such a case must be presided over by a lawyer.
Link to Opinion
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State v. De Anda III, 434 P.3d 1183 (Ariz. 2019)
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Arizona | 2019 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2019
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingBefore Defendant was asked if he would submit to a blood test, the police officer told Defendant his driving privileges would be suspended if he refused. Defendant took the blood tests that resulted in his arrest for driving under the influence (DUI). Defendant moved to suppress the blood test results, arguing that under State v. Valenzuela, 371 P.3d 627 (Ariz. 2016), his consent was involuntary. The trial court denied the motion. The court of appeals affirmed. Reviewing the facts of both Valenzuela and State v. Butler, 302 P.3d 609 (Ariz. 2013), the Supreme Court found the present factual circumstances to be dissimilar. Unlike in Venezuela and Butler, the officer did not "state that Arizona law required [Defendant] to submit to testing. Instead, the form implicitly acknowledged [Defendant] could refuse by asking whether he would submit, although correctly stating that his driving privileges would be suspended if he did not expressly agree to testing." The Supreme Court held that the officer’s identifying the consequences of refusal before asking whether Defendant would submit to the testing did not in itself establish that Defendant’s consent was involuntary.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Before Defendant was asked if he would submit to a blood test, the police officer told Defendant his driving privileges would be suspended if he refused. Defendant took the blood tests that resulted in his arrest for driving under the influence (DUI). Defendant moved to suppress the blood test results, arguing that under State v. Valenzuela, 371 P.3d 627 (Ariz. 2016), his consent was involuntary. The trial court denied the motion. The court of appeals affirmed. Reviewing the facts of both Valenzuela and State v. Butler, 302 P.3d 609 (Ariz. 2013), the Supreme Court found the present factual circumstances to be dissimilar. Unlike in Venezuela and Butler, the officer did not "state that Arizona law required [Defendant] to submit to testing. Instead, the form implicitly acknowledged [Defendant] could refuse by asking whether he would submit, although correctly stating that his driving privileges would be suspended if he did not expressly agree to testing." The Supreme Court held that the officer’s identifying the consequences of refusal before asking whether Defendant would submit to the testing did not in itself establish that Defendant’s consent was involuntary.
Link to Opinion
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State v. Deadwiller, 834 N.W.2d 362 (Wis. 2013)
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Wisconsin | 2013 | Criminal Justice, Police Misconduct and Bias |
State:
Wisconsin
Year:
2013
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was found guilty of two counts of sexual assault by use of force based on DNA evidence that matched defendant to the crime. Defendant invoked the right to confront the witnesses against him contained in the fifth amendment, claiming that the DNA analyst did not appear in court. The Supreme Court found that the DNA profiles were not testimonial and affirmed Defendant's conviction. The Supreme Court reached its decision by applying the U.S. Supreme Court's decision in Williams v. Illinois, 567 U.S. 50 (2012), which addressed a very similar question.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was found guilty of two counts of sexual assault by use of force based on DNA evidence that matched defendant to the crime. Defendant invoked the right to confront the witnesses against him contained in the fifth amendment, claiming that the DNA analyst did not appear in court. The Supreme Court found that the DNA profiles were not testimonial and affirmed Defendant's conviction. The Supreme Court reached its decision by applying the U.S. Supreme Court's decision in Williams v. Illinois, 567 U.S. 50 (2012), which addressed a very similar question.
Link to Opinion
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State v. deLottinville, 890 N.W.2d 116 (Minn. 2017)
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Minnesota | 2017 | Criminal Justice, Access to Justice, Police Misconduct and Bias |
State:
Minnesota
Year:
2017
Topics:
Criminal Justice, Access to Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 2015, Appellant was arrested and charged with two felonies: fifth-degree possession of methamphetamine and storing methamphetamine paraphernalia in the presence of a child. Appellant was granted a pretrial release, so long as she passed random drug testing, and a warrant was issued for her arrest following her failure of several drug tests. A few days later, in response to a tip, police visited Appellant's boyfriend's home. The boyfriend lived in the garden level of his parent's home. Upon arriving, one officer spoke to the boyfriend's mother at the front door, while the second went around back to prevent anyone from fleeing the home. One officer saw Appellant through a back window. The officer entered the home through an unlocked back door, and arrested Appellant, while spotting marijuana, methamphetamine, hydrocodone pills and drug paraphernalia in plain view. On a motion to suppress, the district court ruled that Appellant's arrest was illegal because the warrant for her arrest did not authorize police to enter her boyfriend's apartment. The district court suppressed all fruits of the arrest and dismissed the charges. The court of appeals unanimously reversed, adopting the reasoning of the United States Court of Appeals for the Eighth Circuit in United States v. Clifford, 664 F.2d 1090 (1981), which held that a guest in a home does not have a greater expectation of privacy than the homeowner under the Fourth Amendment. The Supreme Court of Minnesota affirmed holding that the police officer's warrantless entry into the home of Appellant's boyfriend to arrest the Appellant did not violate Minnesota Constitution's prohibition against unreasonable search and seizure because an arrest warrant authorizes police entry into the arrestee's dwelling.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 2015, Appellant was arrested and charged with two felonies: fifth-degree possession of methamphetamine and storing methamphetamine paraphernalia in the presence of a child. Appellant was granted a pretrial release, so long as she passed random drug testing, and a warrant was issued for her arrest following her failure of several drug tests. A few days later, in response to a tip, police visited Appellant's boyfriend's home. The boyfriend lived in the garden level of his parent's home. Upon arriving, one officer spoke to the boyfriend's mother at the front door, while the second went around back to prevent anyone from fleeing the home. One officer saw Appellant through a back window. The officer entered the home through an unlocked back door, and arrested Appellant, while spotting marijuana, methamphetamine, hydrocodone pills and drug paraphernalia in plain view. On a motion to suppress, the district court ruled that Appellant's arrest was illegal because the warrant for her arrest did not authorize police to enter her boyfriend's apartment. The district court suppressed all fruits of the arrest and dismissed the charges. The court of appeals unanimously reversed, adopting the reasoning of the United States Court of Appeals for the Eighth Circuit in United States v. Clifford, 664 F.2d 1090 (1981), which held that a guest in a home does not have a greater expectation of privacy than the homeowner under the Fourth Amendment. The Supreme Court of Minnesota affirmed holding that the police officer's warrantless entry into the home of Appellant's boyfriend to arrest the Appellant did not violate Minnesota Constitution's prohibition against unreasonable search and seizure because an arrest warrant authorizes police entry into the arrestee's dwelling.
Link to Opinion
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State v. Duffy, 486 P.3d 197 (Ariz. 2021)
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Arizona | 2021 | Criminal Justice, Access to Justice |
State:
Arizona
Year:
2021
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant and his codefendant were charged with conspiracy, possession, and transportation of marijuana for sale, and unlawful possession of drug paraphernalia. At Defendant's arraignment, the prosecutor noted his concern about one attorney representing both codefendants. Defense counsel dismissed the concerns because the codefendants had signed a waiver of potential conflict after being advised of their rights. The jury ultimately convicted both Defendants on all counts. The court of appeals vacated the convictions, holding that the joint representation presented an actual conflict that violated Defendant's Sixth Amendment right to conflict-free representation. The Supreme Court affirmed, holding that because the trial court failed to conduct a colloquy with Defendant or any meaningful inquiry into the conflict, Defendant could not have knowingly and intelligently waived the right to conflict-free counsel. As the court of appeals observed, the Supreme Court noted that joint representation prevented Defendant's counsel from exploring a plea bargain and consequently remanded for a new trial.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant and his codefendant were charged with conspiracy, possession, and transportation of marijuana for sale, and unlawful possession of drug paraphernalia. At Defendant's arraignment, the prosecutor noted his concern about one attorney representing both codefendants. Defense counsel dismissed the concerns because the codefendants had signed a waiver of potential conflict after being advised of their rights. The jury ultimately convicted both Defendants on all counts. The court of appeals vacated the convictions, holding that the joint representation presented an actual conflict that violated Defendant's Sixth Amendment right to conflict-free representation. The Supreme Court affirmed, holding that because the trial court failed to conduct a colloquy with Defendant or any meaningful inquiry into the conflict, Defendant could not have knowingly and intelligently waived the right to conflict-free counsel. As the court of appeals observed, the Supreme Court noted that joint representation prevented Defendant's counsel from exploring a plea bargain and consequently remanded for a new trial.
Link to Opinion
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State v. Dunbar, 550 P.3d 142 (Ariz. 2024)
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Arizona | 2024 | Criminal Justice, Access to Justice |
State:
Arizona
Year:
2024
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of attempted murder, aggravated assault with a deadly weapon, and related offenses. Defendant requested to represent himself during the final stages of his resentencing, but the trial court denied his request. Defendant appealed the decision, arguing that his right to self-representation had been violated. The court of appeals agreed with Defendant, concluding that the trial court's denial constituted structural error. The State appealed. The Supreme Court held that erroneous denials of the right to self-representation at sentencing constitute structural error. The Court also clarified that not all denials of self-representation requests are erroneous and provided guidance on the analysis a trial court must employ in determining whether it should grant a defendant’s untimely self-representation request. In particular, a trial court must consider whether the denial of the request would prevent a defendant from being allowed to make their own choices about the proper way to protect their own liberty. The Court vacated parts of the court of appeals’ decision and remanded the case back to the trial court for reconsideration of Defendant's request to represent himself.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of attempted murder, aggravated assault with a deadly weapon, and related offenses. Defendant requested to represent himself during the final stages of his resentencing, but the trial court denied his request. Defendant appealed the decision, arguing that his right to self-representation had been violated. The court of appeals agreed with Defendant, concluding that the trial court's denial constituted structural error. The State appealed. The Supreme Court held that erroneous denials of the right to self-representation at sentencing constitute structural error. The Court also clarified that not all denials of self-representation requests are erroneous and provided guidance on the analysis a trial court must employ in determining whether it should grant a defendant’s untimely self-representation request. In particular, a trial court must consider whether the denial of the request would prevent a defendant from being allowed to make their own choices about the proper way to protect their own liberty. The Court vacated parts of the court of appeals’ decision and remanded the case back to the trial court for reconsideration of Defendant's request to represent himself.
Link to Opinion
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State v. Dunson, 134 N.E.3d 1227 (Ohio 2016), rev'd and remanded, State v. Dunson, 158 N.E.3d 593 (Ohio 2020)
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Ohio | 2016 | Criminal Justice |
State:
Ohio
Year:
2016
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn a similar fact pattern as in State v. Braden, 145 N.E.3d 235 (Ohio 2019), the Defendant owed $6,199.10 for the cost of his jury trial, but only made $40 a month working in the prison system, meaning it would take him 18 years to satisfy the judgment. The courts deducted from his salary automatically, making it difficult for him to afford basic necessities. Unlike Braden, however, the issue before the Supreme Court was not whether O.R.C. 2947.23(C) provides the court with jurisdiction to waive, modify, or suspend court costs for cases in which the defendant's conviction and sentence became final prior to the enactment of the statute. Rather, the issue before the Supreme Court was whether courts must consider the defendant's present or future ability to pay the costs in exercising its discretion to waive, suspend, or modify the costs. Based on a later decision, State v. Taylor, 2018 WL 1989584 (Ohio Ct. App. 2018), rev'd and remanded, State v. Taylor, 163 N.E.3d 486 (Ohio 2020), which held that O.R.C. 2947.23(C) does not require a trial court to consider ability to pay when determining whether to waive or modify court costs, on August 4, the Supreme Court reversed and remanded Dunson to the appellate court for reconsideration consistent with its Taylor decision. The dissent disagreed, noting that the "the majority has adequately considered how O.R.C. 2947.23's purpose—which is to recoup court costs from convicted defendants in order to lighten the burden of paying for criminal proceedings that falls on Ohio taxpayers—affects our analysis." It cites to Braden, noting that "[i]n the case of O.R.C. 2947.23—Ohio's court-costs-recoupment statute—we have stated that the purpose of levying and collecting court costs is to relieve taxpayers of the full burden of financing the criminal-justice system."
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Justice Vote Breakdown
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Summary of Case Context & Holding
In a similar fact pattern as in State v. Braden, 145 N.E.3d 235 (Ohio 2019), the Defendant owed $6,199.10 for the cost of his jury trial, but only made $40 a month working in the prison system, meaning it would take him 18 years to satisfy the judgment. The courts deducted from his salary automatically, making it difficult for him to afford basic necessities. Unlike Braden, however, the issue before the Supreme Court was not whether O.R.C. 2947.23(C) provides the court with jurisdiction to waive, modify, or suspend court costs for cases in which the defendant's conviction and sentence became final prior to the enactment of the statute. Rather, the issue before the Supreme Court was whether courts must consider the defendant's present or future ability to pay the costs in exercising its discretion to waive, suspend, or modify the costs. Based on a later decision, State v. Taylor, 2018 WL 1989584 (Ohio Ct. App. 2018), rev'd and remanded, State v. Taylor, 163 N.E.3d 486 (Ohio 2020), which held that O.R.C. 2947.23(C) does not require a trial court to consider ability to pay when determining whether to waive or modify court costs, on August 4, the Supreme Court reversed and remanded Dunson to the appellate court for reconsideration consistent with its Taylor decision. The dissent disagreed, noting that the "the majority has adequately considered how O.R.C. 2947.23's purpose—which is to recoup court costs from convicted defendants in order to lighten the burden of paying for criminal proceedings that falls on Ohio taxpayers—affects our analysis." It cites to Braden, noting that "[i]n the case of O.R.C. 2947.23—Ohio's court-costs-recoupment statute—we have stated that the purpose of levying and collecting court costs is to relieve taxpayers of the full burden of financing the criminal-justice system."
Link to Opinion
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State v. Earls, 70 A.3d 630 (N.J. 2013)
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New Jersey | 2013 | Criminal Justice |
State:
New Jersey
Year:
2013
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn an effort to locate the Defendant during their investigation, police requested a location trace from the cell phone service provider for a phone they believed Defendant was using. Although police had an arrest warrant for the Defendant, at no point did police obtain a warrant for the cell phone trace. Police found Defendant at a motel near the location identified by the cell service provider and arrested him there. The issue presented to the New Jersey Supreme Court was whether individuals have a reasonable expectation of privacy in the location of their cell phones under the New Jersey Constitution and, in turn, whether a showing of probable cause is needed to obtain a search warrant in order to obtain cell phone location information. This was an issue of first impression, and the Court found that, considering the technical advancements related to cell phones, individuals have a reasonable expectation of privacy in the location of their cell phones and thus a showing of probable cause is required in order to obtain a warrant to obtain cell phone location information. The Court reviewed U.S. Supreme Court case law interpreting the U.S. Constitution's Fourth Amendment in similar contexts, but noted that, on a number of occasions, the New Jersey Supreme Court has found that the N.J. Constitution provides greater protection against unreasonable search and seizures. The Court, in fact, departed from the majority's reasoning in United States v. Jones, 565 U.S. 945 (2012), which decided that the physical installation of a GPS device on a car amounted to a Fourth Amendment search and required a warrant because of the physical trespass. Instead, the New Jersey Supreme Court considered the persuasive authority of the concurring opinions in Jones, which addressed an individual's right to privacy. In Jones, both concurring opinions took the position that the GPS tracking infringed on reasonable expectations of privacy and accounted for the impact of modern tracking devices, which made such tracking easier. Similarly to the Jones concurrences, the New Jersey Supreme Court held that, under the N.J. Constitution, individuals have a reasonable expectation of privacy in the location of their cell phone and that the law must account for modern technology, which has made tracking more precise. The Court also reasoned that the decision did not turn on disclosure to the cell service company because that is not a voluntary third-party disclosure that would alter the phone user's privacy interest. The Court held that the rule would be enforced prospectively only (rather than also retroactively).
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Justice Vote Breakdown
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Summary of Case Context & Holding
In an effort to locate the Defendant during their investigation, police requested a location trace from the cell phone service provider for a phone they believed Defendant was using. Although police had an arrest warrant for the Defendant, at no point did police obtain a warrant for the cell phone trace. Police found Defendant at a motel near the location identified by the cell service provider and arrested him there. The issue presented to the New Jersey Supreme Court was whether individuals have a reasonable expectation of privacy in the location of their cell phones under the New Jersey Constitution and, in turn, whether a showing of probable cause is needed to obtain a search warrant in order to obtain cell phone location information. This was an issue of first impression, and the Court found that, considering the technical advancements related to cell phones, individuals have a reasonable expectation of privacy in the location of their cell phones and thus a showing of probable cause is required in order to obtain a warrant to obtain cell phone location information. The Court reviewed U.S. Supreme Court case law interpreting the U.S. Constitution's Fourth Amendment in similar contexts, but noted that, on a number of occasions, the New Jersey Supreme Court has found that the N.J. Constitution provides greater protection against unreasonable search and seizures. The Court, in fact, departed from the majority's reasoning in United States v. Jones, 565 U.S. 945 (2012), which decided that the physical installation of a GPS device on a car amounted to a Fourth Amendment search and required a warrant because of the physical trespass. Instead, the New Jersey Supreme Court considered the persuasive authority of the concurring opinions in Jones, which addressed an individual's right to privacy. In Jones, both concurring opinions took the position that the GPS tracking infringed on reasonable expectations of privacy and accounted for the impact of modern tracking devices, which made such tracking easier. Similarly to the Jones concurrences, the New Jersey Supreme Court held that, under the N.J. Constitution, individuals have a reasonable expectation of privacy in the location of their cell phone and that the law must account for modern technology, which has made tracking more precise. The Court also reasoned that the decision did not turn on disclosure to the cell service company because that is not a voluntary third-party disclosure that would alter the phone user's privacy interest. The Court held that the rule would be enforced prospectively only (rather than also retroactively).
Link to Opinion
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State v. Edler, 833 N.W.2d 564 (Wis. 2013)
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Wisconsin | 2013 | Criminal Justice, Police Misconduct and Bias |
State:
Wisconsin
Year:
2013
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Eighth Jud. Dist. Ct., 306 P.3d 369 (Nev. 2013)
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Nevada | 2013 | Criminal Justice, Juvenile Justice |
State:
Nevada
Year:
2013
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingLogan D., a minor, was adjudicated delinquent for one count of lewdness with a minor for an offense that occurred when he was 17 years old. At the time of the offense, Nevada law allowed the juvenile court discretion as to whether individuals convicted of sex offenses as juveniles needed to submit to adult sex registration and community notification. Before the juvenile court made a determination as to Logan D., the Nevada Legislature passed Assembly Bill 579, which mandated registration and community notification as an adult for juvenile offenders aged 14 and older and excluded offenders younger than 14 from such requirements. The juvenile court entered an order declaring that the law was an unconstitutional violation of the substantive due process rights of juveniles. The State petitioned the Court for a writ of mandamus that would direct the juvenile court to vacate its order. The Supreme Court granted the petition and held that Assembly Bill 579 (1) was rationally related to protect the public from juvenile sex offenders; (2) did not deny procedural due process to juveniles; (3) was not unconstitutionally vague; (4) did not conflict with the purpose of the juvenile justice system; and (5) did not violate the ex post facto clauses of the United States or Nevada constitutions. Dissenting justices would have held that Assembly Bill 579 violates the ex post facto clauses of the United States or Nevada constitutions. Both the majority and the dissent urged the Legislature to reconsider the mandatory adult sex offender registration and community notification requirements. The Court favored the prior system that allowed the juvenile court discretion to impose such requirements based on a balancing test that considered factors such as "public safety, the welfare of juvenile sex offenders, and conservation of public resources." The Nevada Legislature later repealed Assembly Bill 579 in favor of a multi-part statutory scheme that restored some discretion to juvenile courts, while retaining exceptions for certain aggravated sexual offenses. See Assembly Bill 395, 79th Legislature (Nev. 2017). The new regime also instructs the juvenile court to relieve the child from registration and community notification requirements if the judge finds by clear and convincing evidence that the child has been rehabilitated.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Logan D., a minor, was adjudicated delinquent for one count of lewdness with a minor for an offense that occurred when he was 17 years old. At the time of the offense, Nevada law allowed the juvenile court discretion as to whether individuals convicted of sex offenses as juveniles needed to submit to adult sex registration and community notification. Before the juvenile court made a determination as to Logan D., the Nevada Legislature passed Assembly Bill 579, which mandated registration and community notification as an adult for juvenile offenders aged 14 and older and excluded offenders younger than 14 from such requirements. The juvenile court entered an order declaring that the law was an unconstitutional violation of the substantive due process rights of juveniles. The State petitioned the Court for a writ of mandamus that would direct the juvenile court to vacate its order. The Supreme Court granted the petition and held that Assembly Bill 579 (1) was rationally related to protect the public from juvenile sex offenders; (2) did not deny procedural due process to juveniles; (3) was not unconstitutionally vague; (4) did not conflict with the purpose of the juvenile justice system; and (5) did not violate the ex post facto clauses of the United States or Nevada constitutions. Dissenting justices would have held that Assembly Bill 579 violates the ex post facto clauses of the United States or Nevada constitutions. Both the majority and the dissent urged the Legislature to reconsider the mandatory adult sex offender registration and community notification requirements. The Court favored the prior system that allowed the juvenile court discretion to impose such requirements based on a balancing test that considered factors such as "public safety, the welfare of juvenile sex offenders, and conservation of public resources." The Nevada Legislature later repealed Assembly Bill 579 in favor of a multi-part statutory scheme that restored some discretion to juvenile courts, while retaining exceptions for certain aggravated sexual offenses. See Assembly Bill 395, 79th Legislature (Nev. 2017). The new regime also instructs the juvenile court to relieve the child from registration and community notification requirements if the judge finds by clear and convincing evidence that the child has been rehabilitated.
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State v. Escalante, 425 P.3d 1078 (Ariz. 2018)
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Arizona | 2018 | Criminal Justice, Access to Justice |
State:
Arizona
Year:
2018
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of various drug and weapon-related offenses. At the trial on the drug-related charges, multiple law enforcement officers testified, without objection, about their specialized drug training and described common drug-trafficking methods and drug-courier habits that were consistent with Defendant’s behaviors. The jury found Defendant guilty on all counts, and Defendant appealed the drug-related convictions. The court of appeals affirmed Defendant's drug-related convictions, reviewing for fundamental error whether the trial court correctly admitted the drug-courier profile evidence. The Supreme Court granted review to clarify what a defendant must show to establish fundamental, prejudicial error. The Court held that to show fundamental error, a defendant must demonstrate that the error goes to the foundation of the case, takes away a right essential to the defense, or is of such a magnitude that it denies the defendant a fair trial. To warrant reversal, the defendant must then show prejudice. Notably, if the trial was unfair, prejudice is automatically established. In the instant case, the Court held that because the admission of the drug-courier profile evidence was used as substantive proof of guilt instead of only being used as relevant to demonstrate that Defendant's behaviors were consistent with drug trafficking, fundamental error occurred and prejudice to Defendant’s ability to receive a fair trial. The Court explained that without the drug-courier profile evidence, a reasonable jury could plausibly find Defendant not guilty of the drug-related charges.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of various drug and weapon-related offenses. At the trial on the drug-related charges, multiple law enforcement officers testified, without objection, about their specialized drug training and described common drug-trafficking methods and drug-courier habits that were consistent with Defendant’s behaviors. The jury found Defendant guilty on all counts, and Defendant appealed the drug-related convictions. The court of appeals affirmed Defendant's drug-related convictions, reviewing for fundamental error whether the trial court correctly admitted the drug-courier profile evidence. The Supreme Court granted review to clarify what a defendant must show to establish fundamental, prejudicial error. The Court held that to show fundamental error, a defendant must demonstrate that the error goes to the foundation of the case, takes away a right essential to the defense, or is of such a magnitude that it denies the defendant a fair trial. To warrant reversal, the defendant must then show prejudice. Notably, if the trial was unfair, prejudice is automatically established. In the instant case, the Court held that because the admission of the drug-courier profile evidence was used as substantive proof of guilt instead of only being used as relevant to demonstrate that Defendant's behaviors were consistent with drug trafficking, fundamental error occurred and prejudice to Defendant’s ability to receive a fair trial. The Court explained that without the drug-courier profile evidence, a reasonable jury could plausibly find Defendant not guilty of the drug-related charges.
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State v. Evans, 349 P.3d 205 (Ariz. 2015)
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Arizona | 2015 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2015
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPolice officers pulled over Defendant with concerns of active domestic violence or assault. This ultimately led to Defendant’s arrest for possession of marijuana and drug paraphernalia and driving under the influence. Defendant moved to suppress the evidence on the ground that the officers lacked reasonable suspicion to pull him over. The trial court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed the lower courts' decisions, holding that reasonable suspicion under the Fourth Amendment does not require the State to show that that police officers expressly ruled out the possibility of innocent behavior, and the police officer had reasonable, particularized suspicion that the Defendant was committing an act of domestic violence or assault, as justification for investigatory automobile stop.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Police officers pulled over Defendant with concerns of active domestic violence or assault. This ultimately led to Defendant’s arrest for possession of marijuana and drug paraphernalia and driving under the influence. Defendant moved to suppress the evidence on the ground that the officers lacked reasonable suspicion to pull him over. The trial court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed the lower courts' decisions, holding that reasonable suspicion under the Fourth Amendment does not require the State to show that that police officers expressly ruled out the possibility of innocent behavior, and the police officer had reasonable, particularized suspicion that the Defendant was committing an act of domestic violence or assault, as justification for investigatory automobile stop.
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