State Supreme Court Data Tracker

Summary of Case Context & HoldingDefendant was indicted for charges arising out of a motorcycle accident in 2012. His trial began in 2018. At trial the court determined that the Defendant's constitutional right to a speedy trial had not been violated, despite the long delay between the accident and his trial. He was sentenced to two terms of life imprisonment without the possibility of parole. The court of appeals reversed Defendant's convictions on the grounds of the Sixth Amendment right to a speedy trial. The Supreme Court ruled in this case that a six year delay between Defendant's indictment and the beginning of his trial was "presumptively prejudicial," meaning it is not an ordinary delay. If a delay is presumptively prejudicial, it triggers an analysis to determine whether the defendant was prejudiced by the lack of a speedy trial. The Supreme Court found that when the trial court undertook the analysis it misapplied the speedy trial analysis in two ways. First, the trial court assumed the State was the prejudiced party, but the Defendant was the party who may be prejudiced. Second, the trial court wrongly suggested that the Defendant must prove actual prejudice to win a speedy trial claim. As a result, the Supreme Court remanded the case for the trial court to, among other things, reconsider the quantum of proof required for the speedy trial analysis.

Summary of Case Context & HoldingDefendant was convicted of felony DUI. During her arrest, she failed certain field sobriety tests and refused to submit to a preliminary breath test. After the police obtained a search warrant authorizing a blood draw, it was revealed that Defendant had a blood alcohol concentration of 0.13 percent–well over the legal limit. In the State’s closing argument at trial, the prosecutor made certain comments suggesting that Defendant could have “prove[d] her innocence,” or “exonerate[d] her[self]” by taking the breath test, but she refused to do so. Defense counsel did not object to these statements at trial, but had submitted a pre-trial motion in limine which had asked that the court prohibit the State from making any arguments that would suggest the jury infer from her refusal to take a test that the result would have been positive. On appeal, Defendant argued that the prosecutor’s comments suggesting she could have proven her innocence by providing a breath test were impermissible and constituted prosecutorial misconduct. The Court held that the motion in limine did not preserve the issue for appeal. Rather, if the Court was going to review the issue, it would need to be under the plain error review exception. The Court agreed with Defendant that the prosecutor’s comments were improper, because, “while . . . the prosecution can introduce evidence of a defendant’s refusal to take a breath test to argue the defendant’s consciousness of guilt, the comments complained of in this case–that [defendant] could have ‘proven her innocence’ by submitting to a breath test–have the potential to blur the distinction between a defendant’s state of mind and the State’s burden of proof.” The Court especially took issue with the “repeated use of burden of proof language–such as demonstrate, show, and prove.” Despite the comments being improper, however, the Court declined to exercise plain error review to reverse the trial court’s decision. In so declining, the Court noted that the prosecutor had repeatedly reminded the jury it was his duty to prove guilt beyond reasonable doubt, and that the defense did not have to prove anything. Finally, the prosecutor’s argument relied heavily on evidence other than Defendant’s refusal to submit a breath test.

Summary of Case Context & HoldingThe State charged Appellant with criminal vehicular operation. Appellant moved to suppress ‘‘all evidence of the presence of drugs’’ found in her blood, arguing that the warrant application and supporting affidavit failed to provide a lawful basis to test her blood for controlled substances because the warrant application mentioned the arresting officer believed she was under the influence of alcohol, but did not mention controlled substances, so the issuing magistrate was required to limit any testing to alcohol. The district court granted Appellant’s suppression motion. The State filed a pretrial appeal challenging the district court’s suppression order. The court of appeals reversed. The Supreme Court of Minnesota affirmed concluding that the warrant application and supporting affidavit provided probable cause to believe that evidence of criminal vehicular operation would be found in Appellant’s blood because the warrant was sent to "an approved lab for testing," specified the tests to reveal "evidence of the crime of criminal vehicular operation/homicide," and the facts established probable cause to believe evidence of criminal vehicular operation would be found in the Appellant's blood, though unknown whether the intoxicant was alcohol, controlled substances, or some combination thereof, and that as a result the warrant satisfied the Particularity Clause in the Fourth Amendment. In dissent, Justice Stras argued that the warrant application established probable cause only for the presence of alcohol in the Appellant's blood, not the presence of a controlled substance generally, because Appellant's behavior did not indicate likelihood that they were under the influence of controlled substances. Additionally, Justice Stras noted that under a different set of facts, it would be worth considering whether good-faith exception would not require the suppression of evidence when law enforcement, without engaging in misconduct, proceeds under a defective search warrant. In a separate dissent, Justice Lillehaug agreed with Justice Stras regarding the scope of the probable cause claim, but disagreed with Justice Stras' claim regarding what a proper application of the good faith exception would look like.

Summary of Case Context & HoldingDefendant appealed the trial court's failure to suppress evidence obtained from wiretaps, arguing that the wiretap orders failed to protect the Defendant's constitutional rights because the orders allowed for continued interception of a newly identified phone, allowing police to intercept facilities not specified in the wiretap orders. The Court noted that it has the power to construe a statute to free it from constitutional doubt, and directed that future orders for roving wiretaps should direct the State to notify the wiretap judge within 48 hours after the State begins interception of a new facility. The Court provided further guidance that the report to the wiretap judge should identify the new facility, relay when interceptions began, and explain the basis for switching to the new facility. The wiretap judge can then determine if there is probable cause to believe that the target identified in the original application has used or will be using the new facility and communications about the offenses identified in the original application that may be obtained from the new facility. The Court further directed that reports be submitted within 48 hours of the start of the interception of the new facility, and that the State may, under N.J.S.A. 2A:156A-13, informally apply for authorization to begin monitoring a telephone without a court order in the case of an emergency that involves conspiratorial activities of organized crime or immediate danger of death or serious bodily injury to any person. Within 48 hours of receiving verbal approval, the State must apply for a formal order. For a roving wiretap, if it is not practical for the State to submit the report within 48 hours, the Court directed that the report should be submitted as soon as possible with an adequate justification for such delay. In issuing this direction and guidance for future cases, the Court explained that the procedures will eliminate doubts raised by the Defendant regarding the roving wiretap provision under the State Constitution while also preserving the intended scope of the statute the legislature enacted.

Summary of Case Context & HoldingThe Defendant was charged with aggravated murder in addition to several other charges for which he pled not guilty. Before trial, there were conflicting reports administered years prior, but the psychologist concluded that the results likely underestimated the Defendant's intelligence and found the Defendant intellectually able. The defense moved to dismiss the death specification based on IQ, but the trial court overruled the motion and the jury found him guilty of all charges and specifications and returned a death sentence on one of the counts. The Supreme Court held, among other things, that trial courts must consider a defendant's IQ test scores in determining intellectual disability (overruling State v. Lott, 779 N.E.2d 1011 (Ohio 2002)). Specifically, courts need to consider the following elements: (1) intellectual-functioning deficits (indicated by an IQ score approximately two standard deviations below the mean—i.e., a score of roughly 70 or lower when adjusted for the standard error of measurement); (2) significant adaptive deficits in any of the three adaptive-skill sets (conceptual, social, and practical); and (3) the onset of these deficits while the Defendant was a minor. The case also analyzed which statements police could make to a subject regarding the death penalty and regarding life sentences, under which conditions, before any confession would be considered coerced by threats regarding sentencing. First, the defendant argued the detectives mislead him about his DNA being identified on evidence and that his conversations with his cellmate had been recorded. The Supreme Court held that while the "tactic of lying to a suspect about the evidence is not in itself sufficient to render a confession involuntary . . . the fact that the detectives misrepresented the evidence is a relevant factor in evaluating whether the totality of the circumstances renders the confession involuntary." Second, the defendant argued that "the detectives coerced his confession by telling him that they would be asked to comment on Ford's cooperativeness when the case was presented to the grand jury, because it would be a factor in deciding whether the state would seek the death penalty." The Supreme Court held that officers may inform of the advantages of telling the truth and its not unduly coercive for an officer to mention punishments. Accordingly, because the detectives did not promise leniency and did not misstate the law in telling him that the death penalty was a potential punishment, the court held that these statements did not coerce the defendant. Fourth, the defendant argued that the possibility of a lesser sentence was available if he told the truth, and the court held that "admonishing" the defendant simply to tell the truth was not unduly coercive. Finally, the defendant argued that the detectives told him that he was looking at an "automatic" death sentence, even though the death penalty is never automatic under O.R.C. 2929.03(D)(2) and (3). The Supreme Court held that a review of the video of the defendant's interview does not show that the references to the death penalty were threats "or that their remarks resulted in Ford's will being overborne."

Summary of Case Context & HoldingAfter a bench trial, the Defendant was charged with fifth-degree felony possession of cocaine. The charge stemmed from the results of drug testing that was performed soon after Defendant gave birth to her son, J.B., which showed the presence of cocaine metabolites in the umbilical-cord tissue and in J.B.’s urine and meconium. Defendant argued that the state did not establish venue for possession of cocaine because assimilation of a foreign substance into a person's body (like the metabolization of drugs) does not qualify as possession and therefore the state did not have sufficient evidence to show that she possessed cocaine in the county. The Supreme Court unanimously ruled that the mere presence of drug metabolites in the body is insufficient to establish possession of said drug (a strategy used in the past to constructively prosecute people for the status or condition of being a "drug user").

Summary of Case Context & HoldingAppellant was found guilty by jury of first-degree premeditated murder and first-degree felony murder arising out of the December 2011 stabbing death of Appellant’s girlfriend. Upon his arrest, Appellant was interviewed by police officers. Before officers had an opportunity to give Appellant his Miranda rights, Appellant volunteered ‘‘Well this about, you know what I’m sayin’ my girl’s car man you know you can tell her she lived with me . . . .’’ Officers interrupted Appellant, read him his rights, and Appellant affirmed that he understood those rights. Appellant offered some details about where he was during the period of the crime, and his using of the victim’s credit card. The next day, Appellant asked to speak with the police officers. At the beginning of the interview, Appellant was reminded of his Miranda rights and agreed to waive them. During the interview, Appellant informed the officers that he had contacted the Public Defender’s Office earlier in the day, asking for representation, and was told that a public defender could not represent him until he was formally charged. The police told Appellant they could not advise him and asked him if he wanted to talk to a lawyer. Appellant stated that he did not. Unbeknownst to the police officers, two public defenders talked to jail staff and asked to meet with Appellant about 2 hours before Appellant’s interview with the police. Jail staff did not permit the public defenders to meet with Appellant, but neither Appellant nor the interviewing officers were aware of the public defenders’ attempt to meet with Appellant. The district court entered judgment of conviction on both counts and sentenced Appellant to life imprisonment without the possibility of release on the first-degree premeditated murder conviction. On direct appeal, Appellant argued that the district court erred because the district court denied his motion to suppress statements he made to police. The Supreme Court of Minnesota concluded Appellant’s arguments that his waiver of Miranda rights was not knowing or intelligent lacked merit. Specifically, while officers failed to obtain Appellant’s express waiver of his Miranda rights, upon the totality of the circumstances, the Supreme Court of Minnesota concluded that Appellant impliedly waived his rights, based on the colloquy between Appellant and the officers which showed Appellant was given the Miranda warnings, affirmatively stated that he understood his rights, and proceeded to voluntarily participate in the interview.

Summary of Case Context & HoldingAppellant was convicted in the district court of three counts of murder in connection with the death and alleged sexual assault of his 2-year old niece. He appealed, and while his appeal was pending, the trial court granted a new trial based on identification of new evidence. Following the new trial, Appellant was convicted in the trial court of five counts of murder. On direct appeal, he alleged that the district court committed reversible error in the retrial when it: (1) seated two jurors who knew that the first trial had resulted in a conviction; (2) seated a juror actually biased against the Appellant; and (3) admitted evidence of Appellant's alleged sexual abuse of a relative. With respect to (1), the Supreme Court addressed the doctrine of implied bias in the Minnesota criminal code and determined it was not warranted here because Minnesota law is clear as to when prospective jurors are too connected to a case at issue to sit (circumstances that were not present in the case at hand). With respect to (2), the Supreme Court held that the jury was biased because the juror disclosed on his juror questionnaire that his mother in law was working in the emergency room where the victim was being treated and died after the alleged assault, had spoken with family and friends who had personal knowledge of what had happened at the hospital with the victim, and never unequivocally claimed that he could decide the case based only on the facts in the courtroom. As a result, the conviction was reversed and remanded for a new trial. With respect to (3), the Supreme Court noted that because the issue would come up again at the new trial, it would clarify its view on the subject, and held that evidence of domestic conduct by an accused against a family or household member of the victim may be admitted unless its probative value is substantially outweighed by danger of unfair prejudice, confusion of the issue, or misleading the jury, or by considerations of undue delay, waste of time, or the needless presentation of cumulative evidence.

Summary of Case Context & HoldingDefendant was convicted in a jury trial in the district court of sexual intercourse without consent. The victim reported the incident four years after it took place, indicating that she came forward after seeing a newspaper article reporting that Defendant had been accused of molesting a five-year old boy. At trial, Defendant moved to suppress any testimony regarding the case described in the newspaper because it was more prejudicial than probative and because he had been acquitted of those charges. The State indicated that it intended to offer testimony explaining that the victim's delayed disclosure was prompted by the newspaper article. The district court held a hearing on the motion to suppress and decided the testimony was not offered as evidence of Defendant's character, but rather to explain the timing of the victim's disclosure, and was therefore admissible. The district court allowed Defendant to offer evidence that he was acquitted of those charges. At trial, however, the victim repeatedly mentioned that the article made her feel like she “was not the only victim” and that she “knew that there was . . . another person that had had the same thing done to them that was done to [her].” She also testified that she had told a few of her friends prior to seeing the article. Defendant moved for a new trial because he claimed the evidence/testimony failed to bear out the State’s theory that the newspaper article had prompted the victim’s disclosure. The Court held that the probative value of the evidence concerning the other molestation charges was substantially outweighed by danger of unfair prejudice because the State did not limit its use of the testimony to explaining the timing of victim’s disclosure. In addition to questionable causation between the newspaper and victim coming forward, the prosecutor had made certain comments at trial implying that Defendant was a serial child molester who had simply gotten away with it.

Summary of Case Context & HoldingFuqua, the Defendant, checked into a Studio Motel 6 in late September 2011, where he was found with Johnson, another defendant, together with 6 children between the ages of one and thirteen, three of which were Defendant's children, one was Johnson's child and two were the Defendant's relatives. In the unit, the officers found marijuana and other items related to drug packaging and distribution. Johnson pled guilty to drug distribution charges and a jury convicted the Defendant of endangering the welfare of children. The Defendant made a motion for a judgment of acquittal, which the trial court denied holding that the State does not need to prove actual harm to children to convict the Defendant under N.J.S.A. 2C:24-4 (Endangering the Welfare of a Child), a crime which can carry a mandatory prison term of 5-10 years if it is charged in the second degree. The Appellate Division affirmed, holding that the phrase “causes harm” in N.J.S.A. 2C:24-4(a) refers not only to one who causes actual harm, but also to one who “unreasonably allows a substantial risk of harm.” The Supreme Court addressed the issue of whether the “harm” to a child which causes him or her to be abused or neglected must be actual or whether the exposure to a “substantial risk” of harm is sufficient to sustain a conviction under N.J.S.A. 2C:24-4(a)(2). The Supreme Court ultimately affirmed the lower court's ruling, and held that (i) the State is not required to prove actual harm to a child to convict for endangering the welfare of a child; (ii) sufficient evidence supported Defendant's conviction for endangering the welfare of a child, under the reasoning that the potential access to the drugs posed an imminent danger to the children; and (iii) the prosecutor did not abuse her discretion in choosing to charge Defendant with second-degree endangering the welfare of a child.

Summary of Case Context & HoldingGabriel was convicted of attempted first-degree murder of a law enforcement officer with a firearm, resisting an officer with violence, attempted robbery with a firearm, and aggravated assault with a firearm. The Fifth District Court of Appeal reversed the attempted first-degree murder conviction. On remand, Gabriel was resentenced for attempted robbery with a firearm (primary offense), aggravated assault with a firearm (additional offense), and resisting an officer with violence (additional offense). The Criminal Punishment Code (CPC) Scoresheet indicated the lowest permissible sentence (LPS) was 107.25 months, and the trial court agreed with the State that the LPS is an individual minimum sentence that must be applied to each offense before the sentencing court if the LPS exceeds each individual statutory maximum sentence. On appeal, Gabriel argued that his sentences for aggravated assault with a firearm and resisting an officer with violence are unlawful because they exceed the statutory maximum for those offenses. Ultimately, the Fifth District reversed the trial court, and certified the following question to the Supreme Court of great public importance: Is the lowest permissible sentence as defined by and applied in Section 921.0024(2), Florida Statutes, an individual minimum sentence and not a collective minimum sentence where there are multiple convictions subject to sentencing on a single scoresheet? Agreeing with the State's argument that, based on the plain language of Section 921.0024(2), the LPS is an individual minimum sentence, the Supreme Court ultimately answered the certified question in the affirmative concluding that under Section 921.0024(2), the LPS is an individual minimum sentence where there are multiple convictions subject to sentencing on a single scoresheet.

Summary of Case Context & HoldingDefendant was convicted of unlawful possession of a weapon and resisting arrest. Defendant appealed and the Appellate Division reversed. The State petitioned for certification. The appeal involved the validity of a warrantless search of a van and the seizure of a handgun from the van's center console. The initial investigatory stop, the subsequent frisk of the occupants, and the protective search of the passenger compartment of the van were precipitated by two late night anonymous calls to the police, the first reporting shots fired and the second reporting an individual seated in a van with a gun on his lap. The location identified by both calls was well-known to the responding police officers as a high-crime area. The Supreme Court held that the totality of the circumstances, including the 911 calls, the late hour, the location of the van, frantic movements of the occupants, and the hesitancy of the driver to leave the van, permitted the responding police officers to form a reasonable suspicion that either one or both of the occupants of the van were armed or that a weapon would be found in the vehicle. The Supreme Court reversed the judgement of the Appellate Division.

Summary of Case Context & HoldingThe State and defense counsel presented two different versions of the facts at trial. The State's witnesses claimed that Defendant, unprovoked, attacked another person with a knife when that person approached him about the honking of his car's horn. The defense witnesses claimed that the victim and two other men armed with weapons attacked Defendant for honking his horn and, in self defense, Defendant defended himself with a box cutter. At trial, the prosecution implied that the defense witnesses were lying that Defendant acted in self defense. To rebut this evidence, defense counsel attempted to introduce a video taken at the scene showing that the defense witnesses attempted to explain this to police at the scene but were told to "take it to court" by police. The trial court ruled the evidence was inadmissible hearsay so it was not shown to the jury. The prosecution then proceeded to argue in closing that, had defense witnesses actually observed Defendant acting in self defense, they would have approached police at the scene. The issue before the New Jersey Supreme Court was whether, under the plain error doctrine, the exclusion of the video and the prosecutor's remarks denied Defendant a fair trial. The Court held that the video recording was admissible extrinsic evidence as an exception to hearsay to rebut the charge of fabrication by the prosecution. Further, the Court held that the exclusion of the recording and the prosecutor's improper exploitation of the exclusion during the closing argument amounted to plain error.

Summary of Case Context & HoldingAriz. Rev. Stat. 13-753(B) provides that the trial court shall order a pretrial intellectual disability (ID) evaluation in every capital case unless the defendant objects, and if the defendant objects, the defendant waives the right to a pretrial evaluation. In the instant case, more than two years after filing his objection to an ID evaluation and four months before the scheduled trial, Defendant moved to withdraw his objection to court-ordered testing. The trial court granted the motion, concluding that Ariz. Rev. Stat. 13-753(B) permitted Defendant to reinstate his right to a pretrial ID evaluation by withdrawing his objection. The Supreme Court vacated the trial court’s order and remanded the case for consideration of Defendant’s request for an ID evaluation, holding (1) a defendant cannot void his waiver under Ariz. Rev. Stat. 13-753(B) by later withdrawing his objection; but (2) a defendant’s waiver does not deprive the court of its discretionary authority to order a pretrial ID evaluation if the defendant later requests or consents to one.

Summary of Case Context & HoldingPetitioner James Giles was convicted of first-degree burglary, strong arm robbery, and kidnapping. He was sentenced to thirty years, thirty years, and fifteen years, respectively, to be served concurrently. On appeal to the Supreme Court, he argued that the trial judge erred in failing to follow the three-step process outlined in Batson v. Kentucky, 476 U.S. 79 (1986) for determining whether a peremptory juror challenge was based on race. During jury selection, Petitioner used his peremptory challenges to strike eight white males and two white females. The State requested that the trial judge conduct an inquiry as to whether Petitioner had a race neutral reason for striking the ten white jurors. Petitioner's counsel's reason was that petitioner "did not feel the jurors were right for the jury." The State argued that this reason was "highly race based." The trial judge agreed and concluded that while the reason given by Petitioner for the strikes was racially neutral on its face, it was not a sufficient reason under Batson to move the process to the third step, where the burden would be on the State to show the reason given was mere pretext. The trial judge found that if the process proceeded to the third step, it would be impossible for the State to demonstrate Petitioner did not strike the jurors on the basis the prospective juror was not right for the jury. On appeal, Petitioner contended that because the trial judge found Petitioner's reason for striking the jurors was race neutral, he should have proceeded to step three of the Batson process and required the State to prove the reasons given was mere pretext and that Petitioner engaged in purposeful discrimination in exercising his peremptory challenges. The Supreme Court disagreed. The Court held that in order for the explanation provided by the proponent of a peremptory challenge at the second stage of the Batson process to be legally sufficient, while it need not be persuasive or even plausible, it must be clear and reasonably specific such that the opponent of the challenge has a full and fair opportunity to demonstrate pretext in the reason given, and the trial court has the ability to assess the plausibility of the reason in light of all the evidence. The Court overruled State v. Adams, 470 S.E.2d 366 (1996), which held that the proponent of a peremptory challenge has no burden of presenting a reasonably specific and legitimate explanation for the challenge at the second step of the Batson process. The Supreme Court affirmed the lower court determining that the explanation offered by Petitioner fell far short of an articulable reason that would enable the trial court, in the third step of the Batson process, to assess the plausibility of the proffered reason for striking the potential jurors. Instead of being clear and reasonably specific, the reason given by Petitioner was very general and based entirely on Petitioner's overall subjective dissatisfaction with the prospective jurors.

Summary of Case Context & HoldingWhile executing a warrant authorizing the search of a home, police found Defendant, who was not named in the warrant, in the home. Police proceeded to search Defendant’s purse. Defendant was subsequently charged with possession of drugs and drug paraphernalia. Defendant moved to suppress the evidence found in her purse, arguing that the search of her purse was unlawful because she was not named in the warrant. The trial court denied the motion, concluding that police were permitted to search the purse. The Supreme Court reviewed a split in jurisdictional treatment on the possession test, which under United States v. Teller, 397 F.2d 494 (7th Cir. 1968), allows officers to search personal items, such as purses or clothing, that are not in the owner's possession when the police find them in executing a premises search warrant. The Supreme Court affirmed after adopting the possession test, holding that because Defendant did not physically possess her purse when the officers found it, they were authorized to search it for the items listed in the warrant.

Summary of Case Context & HoldingThe Supreme Court held that Defendant had adequately preserved a challenge to the sufficiency of the State's evidence by filing a motion to dismiss at the close of the State's case. The Defendant's motion to dismiss did not specifically assert that the State's evidence was insufficient. The decision rested on the Court's interpretation of the Rules of Appellate Procedure, specifically Rule 10(a)(3), and abrogated the Court's previous ruling in State v. Benson, 66 S.E.2d 893 (N.C. 1951) which predated Rule 10(a)(3). Rule 10(a)(3), of North Carolina's Rules of Appellate Procedure, regulated the preservation of a defendant's challenge to the sufficiency of the evidence. According to the Supreme Court, the rule did not require the Defendant to assert specific grounds for why the evidence is insufficient when moving to dismiss the case. In Benson, the Supreme Court held that if a defendant wanted to challenge the sufficiency of evidence, they must argue a specific insufficiency of the evidence to preserve the issue for appellate review. The Supreme Court overruled Benson to the extent it conflicted with Rule 10(a)(3) which came into effect after Benson.

Summary of Case Context & HoldingTwo police officers were patrolling an area that they “believed to be a ‘high-crime area’ known for shootings and drug dealing,” when they observed two individuals standing in front of a vacant house. When the officers exited their vehicle, the two individuals walked away. At the same time, Defendant exited the walkway that led to the rear of the vacant house. Police approached Defendant, blocking his path, and conducted an investigatory stop of Defendant. According to the officer, Defendant “became nervous,” “looked up and down the street,” and was “sweating, and his hands began to shake.” Defendant provided the officers with a name and informed them that his identification was in his pocket. The police said they would retrieve the ID from Defendant's pocket and Defendant responded that he would appreciate it if they would not pat him down. Police said this statement raised their suspicions further and conducted a pat down of Defendant, finding a handgun. Police arrested Defendant and later found drugs on Defendant and in the walkway by the house. The officer testified at the suppression hearing that based on his training, 20 years of experience, and his belief that the vacant house was used for the sale of drugs and weapons, he “found it suspicious that [D]efendant was on the walkway next to the vacant house and believed [D]efendant was engaged in drug dealing activity.” The issue before the New Jersey Supreme Court was whether reasonable and articulable suspicion existed when the police officer conducted the investigatory stop. The Supreme Court held that the information the officers possessed at the time of the stop did not amount to a specific and particularized suspicion that Defendant was engaged in criminal activity. Accordingly, Supreme Court determined that the officers did not have reasonable and articulable suspicion to initiate an investigatory detention of Defendant, and the evidence seized must be suppressed.

Summary of Case Context & HoldingThe issue presented for the New Jersey Supreme Court's review was whether a trial court, after finding a defendant competent to stand trial on criminal charges, could compel the defendant to assert an insanity defense based on the evidence presented, when the defendant refused to assert such defense. Defendant was charged under a superseding indictment with stalking and weapons charges. The trial court concluded that the Defendant was competent to stand trial, and the Defendant declined to assert an insanity defense. The trial court concluded that Defendant's delusional condition had limited her ability to knowingly, intelligently and voluntarily determine whether to raise the defense, and then asserted the defense on her behalf on the stalking charge. Defendant was found not guilty by reason of insanity on that charge, and convicted on the weapons charges. Defendant appealed her conviction, challenging the trial court's decision to assert the insanity defense on her behalf, and also raising several trial errors. The Appellate Division reversed the trial court's judgment on the insanity defense, and remanded for a bifurcated hearing on the insanity defense and the substantive defenses. The Supreme Court remanded for reconsideration as to the insanity defense and on remand, the Appellate Division affirmed the trial court's judgment of acquittal by reason of insanity on the stalking charge. The Supreme Court held that in light of the trial court's finding that Defendant was competent to stand trial, and the court's detailed explanation of the potential benefits and risks of the insanity defense in a colloquy with Defendant, the trial court should have permitted Defendant to decide whether or not to assert the defense. Accordingly, the Court reversed the trial court's judgment of acquittal by reason of insanity on the stalking charge. The case was remanded for a new competency determination and, if appropriate, a new trial on that charge. Because Defendant's delusion was unrelated to her conviction for the two weapons offenses, and the trial errors that she alleged did not deprive her of a fair trial, the Supreme Court affirmed her conviction for those offenses.

Summary of Case Context & HoldingDefendant was arrested for a series of violent crimes against 33 victims and charged with 74 felonies, including nine counts of first-degree murder, for which the State sought the death penalty. At trial, the charges were joined, and the State presented its case in 13 “chapters,” as permitted by the court. Defendant was convicted on all nine murder counts, and upon his automatic appeal to the Supreme Court, his conviction was affirmed. The Court upheld the three search warrants, finding each supported by probable cause, and rejected claims that consumptive DNA testing violated due process or confrontation rights, noting defense counsel's objections, access to reports, and cross-examination of experts. The Court also upheld the denial of severance, finding the offenses were properly joined due to their similarities and relevance to proving identity, the central issue. The Court found no error in admitting other-act evidence, allowing segmented opening statements, or the handling of defense counsel complaints, as Defendant chose to continue representation. The Court rejected arguments that media exposure tainted witness identifications, finding no state involvement. The Court upheld admission of firearm expert testimony and an autopsy photo, finding their relevance outweighed any prejudice. The Court also rejected third-party culpability claims based on hearsay, found sufficient evidence to deny acquittal, and affirmed the jury's finding of especially cruel murders and use of overlapping evidence for multiple aggravators as not violating Double Jeopardy. The Court found any prosecutorial misconduct not to be a fundamental error and held that Defendant waived mitigation. The Court then determined there to be no abuse of discretion in the imposition of the death sentence and affirmed.

Summary of Case Context & HoldingThe Defendant challenged the requirement that he enroll in a satellite based monitoring (SBM) program and wear an ankle monitor for the rest of his life because of two sex crimes he committed at ages 17 and 26. He fully served his criminal sentences for both crimes. Due to these two offenses, the Defendant was subject to North Carolina's SBM program for recidivists. The Supreme Court held that the state's SBM program for recidivists implicated and violated the Fourth Amendment's prohibition on unreasonable searches. The Fourth Amendment was implicated because the court found that the Defendant had a reasonable expectation of privacy relevant to the mandatory lifetime SBM program, which was considered a search. The Supreme Court reasoned that the government's interest in law enforcement did not outweigh the program's intrusion upon the Defendant's privacy interest. As a result, the SBM program violated the Defendant's right to be protected from unreasonable searches and seizures.

Summary of Case Context & HoldingFollowing an attempted robbery of an acquaintance, Defendants were stopped by police officers on the campus of Drew University. The officers discovered a gun under the driver's seat of the acquaintance's car within reach of Defendants. Defendants were arrested and charged in a twelve-count indictment with various offenses, including third-degree unlawful possession of a weapon at an educational institution. The trial court, in its instruction to the jury, did not state that to find Defendants guilty of unlawful possession of a weapon at an educational facility, the jury must find Defendants knew they were at an educational facility. The jury subsequently convicted Defendants of multiple counts, including third-degree unlawful possession of a weapon at an educational institution. On appeal, the Supreme Court sought to construe the culpability requirement under the statute which criminalizes the knowing possession of a weapon at an educational institution. The Supreme Court held that in order to prove a violation of the statute, the State must prove beyond a reasonable doubt both that a defendant knowingly possessed a weapon and that he or she did so while knowingly on the property of an educational institution. Further, the Supreme Court held that the jury instructions at the trial court level, which did not specify that the jury was required to find Defendants were knowingly at an educational institution, were therefore flawed, and Defendants' convictions of third-degree unlawful possession of a weapon at an educational institution must be vacated.

Summary of Case Context & HoldingIn 1995, Defendant pled guilty to forgery and bail jumping (failing to show up in court and then failing to surrender within a set time period) and was sentenced to twenty years with the Department of Corrections with ten years suspended. The sentence subjected Defendant to various conditions during the suspended portion of his sentence, including a condition that he remain in compliance with all rules and regulations of the Department of Corrections and Human Services, Adult Parole and Probation Bureau (Department). If Defendant violated any of the rules and regulations, Defendant would be subjected to immediate arrest and a hearing before the district court on whether his suspended sentence should be revoked. Less than a year after he began serving time, Defendant escaped. He was then convicted of separate crimes in Washington and Oregon, where he was serving time until 2011 when the Department learned of his status. The State filed a petition to revoke the suspended sentence, maintaining that Defendant had been “on the run” since 1996 and had failed to report as required under the condition of his suspended sentence. At his revocation hearing, Defendant indicated that he was incarcerated or under supervision for most of the time between his 1997 arrest in Washington and the State’s petition to revoke his suspended sentence in 2011. Defendant argued that despite the fact that he could have easily been located at any time during those 14 years, the State took no action and never attempted to inform him that he was considered a probationer or have him sign a copy of the conditions of probation. The most relevant issue for purposes of the appeal was that, at the revocation hearing, Defendant attempted to admit evidence from Washington and Oregon proving that Montana justice authorities could have known his whereabouts and therefore had a duty to call him in to report for probation. At the start of the revocation hearing, the district court informed Defendant that it “would let [him] put in whatever he thought he needed to preserve the record [for] appeal.” At the hearing, however, the district court did not allow certain evidence to be admitted, finding that it could not be properly authenticated. The district court revoked the suspended sentence and sentenced Defendant to ten years in jail. On appeal, Defendant argued that the district court violated his due process rights when it first represented that he could admit whatever documents he wished and subsequently refused to admit evidence from Washington and Oregon over authentication concerns. He argued that he relied on the assurances and would have secured sufficient witnesses were it not for such assurances. The Court agreed, holding that the minimum due process requirements for a revocation hearing are that the probationer be given the opportunity to present documentary evidence, and the process should be flexible to permit letters, affidavits, and other material that would not be admissible in an adversary criminal trial. However, the Court held that the district court's error in refusing to admit out-of-state documents was harmless because the Court rejected Defendant's argument that he was not required to report as required under the condition of his suspended sentence for other reasons and admission of these documents would not have changed that analysis of the Court. As a result, the Court affirmed the district court's judgment.

Summary of Case Context & HoldingDefendant was convicted of sale of narcotics based in part on recorded statements made to an undercover police officer during a drug transaction. The officer stopped Defendant at a bus stop and asked Defendant to get him crack cocaine. Defendant agreed to obtain $20 worth of cocaine for a $10 fee and drove the officer to an apartment complex where Defendant left the car and returned with cocaine in exchange for the money. During trial, Defendant asked the trial court to instruct the jury on the entrapment defense, but the court declined the request because Defendant did not admit by testimony or other evidence to the substantial elements of the offense charged. On appeal, the Supreme Court held that (1) to claim entrapment as a defense Defendant needed to affirmatively admit to the elements of the offense; (2) affirmative admission of the elements of the offence did not violate the Fifth Amendment; and (3) Defendant failed to affirmatively admit the substantial elements of the crime charged and therefore could not claim entrapment. The Court explained that a defendant could not invoke the defense of entrapment by solely declining to challenge the state’s evidence because the statute codified long held common law established by the Arizona Supreme Court requiring admission of substantial elements of the offense and not permitting merely declining to challenge the state’s evidence. Additionally, the Court noted that the Arizona Supreme Court had already rejected a broader interpretation of the defense under federal law established by the U.S. Supreme Court in Mathew v. United States, 485 U.S. 58 (1988). With regard to the Fifth Amendment, the Court explained that Defendant has a choice whether to assert the entrapment defense or stay silent and is therefore not compelled to be a witness against himself. From a policy perspective, the Court noted it might agree the defense should be more widely available, but because the legislature had limited the statute, a change was within the legislature’s purview not the Court’s. The Court held the trial court did not abuse its discretion in declining Defendant’s use of the defense and affirmed Defendant’s conviction and sentence.

Summary of Case Context & HoldingIn 1996, Defendant was convicted of first-degree murder, robbery, and related crimes, and was sentenced to death. In 2020, Defendant filed a post-conviction relief petition alleging that his death sentence was now unconstitutional as a consequence of 2019 legislative amendments that narrowed the statutory circumstances that a jury may consider in determining whether to impose a sentence of death. The Superior Court of Pima County granted relief and vacated Defendant's death sentence. The State's petition for review was granted and the Supreme Court reversed and affirmed Defendant's sentence, holding that the sentence was lawfully imposed and did not violate Defendant's constitutional rights under either the United States or Arizona Constitutions because the amendments were prospective only and the death sentence was constitutional.

Summary of Case Context & HoldingIn this case detectives saw potted marijuana plants within the curtilage of Defendant's home while parked in Defendant's driveway. The detectives seized the plants without a search warrant for the home. At trial the Defendant was convicted of the manufacture of a controlled substance. The appellate court reversed the conviction on the grounds that the evidence of the marijuana plants should not have been introduced because it was a search and seizure that violated the Fourth Amendment's prohibition on unreasonable searches and seizures. The Supreme Court reversed the appellate court, citing the plain view doctrine. The plain view doctrine allows for the warrantless seizure of evidence of a crime when such evidence is clearly visible, as the marijuana plants were. The Supreme Court reasoned that because any member of the public who came to the Defendant's door could have seen the marijuana plants, the Defendant had no privacy interest in the plants. Since there can be no search under the Fourth Amendment without a privacy interest, and since the warrantless seizure of the plants was justified under the plain-view doctrine, the Supreme Court found no Fourth Amendment violation in this case.

Summary of Case Context & HoldingDefendant was charged with and convicted of first-degree murder and kidnapping committed in 2002 and was sentenced to death. Defendant was permitted to represent himself after the trial court found him competent to stand trial and waive his right to counsel. He pleaded guilty and moved on to the aggravation phase. During the aggravation phase, Defendant presented virtually no mitigation evidence, but requested leniency, and the jury sentenced him to death. The Court initially vacated the death sentence and remanded due to an error in the jury’s finding regarding an aggravating factor. On remand, Defendant again waived his right to counsel, presented no mitigation evidence, and did not request leniency, and the jury again determined Defendant should be sentenced to death. The Supreme Court addressed a number of issues on appeal following the remand. First the Court held that self-representation during the penalty phase was not erroneous because the trial court repeatedly found Defendant competent and, against strong advice of the court and counsel, he chose to represent himself. Consistent with prior precedent, the Court reasoned that a capital defendant’s right to self-representation exists from arraignment through direct appeal. Second, the Court held that the trial court did not err in permitting Defendant to waive presentation of mitigation evidence because he was competent and knowingly and voluntarily waived his right and even had a second chance to do so on remand where he was familiar with the process. Third, the Court found procedural deficiencies in Defendant’s claim about the legal sufficiency of a prior conviction aggravator and, even if there were no procedural errors, the Court held the trial court properly reasoned that Defendant could not contest the legal sufficiency of a prior conviction but rather must dispute the validity of the conviction. Fourth, the Court found that the trial court properly responded to a jury’s question about the order of cases by properly ruling it was not legally relevant because Defendant had stipulated to the earlier conviction. Fifth, the Court ruled that there was not prosecutorial misconduct about the prosecutor’s statement regarding Defendant’s failure to present mitigating evidence because Defendant chose not to present any and did not object to or rebut the statement. The Court affirmed Defendant’s death sentence.

Summary of Case Context & HoldingThe Defendant stole thousands of items of jewelry and personal memorabilia from 46 residents of 12 nursing homes and assisted-living facilities while she was employed as a nurse's aide and was charged with 86 felony counts for varying theft crimes. She entered into a plea agreement where she agreed to plea guilty and pay restitution and at sentencing she received 65 consecutive years (12 months for each sentence). The Defendant appealed and argued that the trial court erred by imposing a sentence that was contrary to Ohio's sentencing statutes and that her aggregate 65-year sentence amounted to cruel and unusual punishment in violation of the Eighth Amendment to the U.S. Constitution. The Supreme Court concluded that, in assessing the extent to which consecutive sentencing is “necessary” under O.R.C. 2929.14(C)(4), and in assessing whether consecutive sentencing is disproportionate thereunder, the trial court must consider the total length of the consecutive sentences that would be imposed. The majority also concluded that O.R.C. 2953.08(G)(2) calls for de novo review of the trial judge’s consecutive-sentence findings, but subject to the statute’s requirement that the appellant has the burden of clearly and convincingly showing that the trial court’s findings are not supported by the record. The State’s motion for reconsideration is pending.

Summary of Case Context & HoldingDefendant was convicted of aggravated assault, aggravated kidnapping, tampering with a witness, and misdemeanor assault after an incident with a domestic partner. On appeal, one of the issues raised was whether the trial court erred in allowing the introduction of evidence regarding the nature of the Defendant's relationship with the alleged victim in order to show a "cycle of violence" and "tension building up to the assault." The testimony offered at trial covered the entire scope of the relationship of the Defendant and his partner, which tended to show an increasingly verbally abusive and dependent relationship, culminating in the physical assault for which the Defendant was convicted. The Court applied the transaction rule in Section 26-1-103 MCA, which provides that "[w]here the declaration, act, or omission forms part of a transaction which is itself the fact in dispute or evidence of that fact, such declaration, act, or omission is evidence as part of the transaction." Applying the rule, the Court held that evidence of a cyclically abusive relationship, though not directly relevant to the essential elements of the charged offense, was necessary to provide a comprehensive and complete picture of the commission of the crime. The Court held that the transaction at issue was "both temporally and factually broad" and therefore "encompasses specific aspects of [the Defendant's] behavior dating back to the beginning of the relationship." Further, the Court considered evidence concerning Defendant's contemporaneous relationships with other women, his using a false name and lying about his past employment, his consumption of alcohol, and the financial aspect of his and his victim's relationship as important to establish the source of tension building up to the assault and to help the jury better comprehend Defendant's motive behind the near deadly assault.

Summary of Case Context & HoldingDefendant was convicted of driving under the influence of alcohol. His original sentence was for six months in prison (all but three days suspended), fines totaling $935 and certain sentencing conditions. Later in the sentencing hearing, the length of Defendant’s suspended sentence was doubled to one year to allow Defendant more time to make the monthly fine payments. The municipal court also instituted a payment plan for the fines and allowed Defendant to pay $100 per month. Defendant appealed and challenged his sentence on the grounds that it violated his due process rights because it was based on his indigency. The Court noted that a criminal defendant's sentence must comport with the due process guarantees of the Fourteenth Amendment to the U.S. Constitution and Article II, Section 17 of the Montana Constitution, and a defendant's "right to due process requires that indigency or poverty not be used as the touchstone for imposing the maximum allowable punishment." Here, the Court found that the municipal court imposed the maximum sentence on Defendant based on his inability to pay the fines. The Court vacated the sentence on due process grounds and remanded for entry of a new sentence that comports with due process. In vacating the sentence, the Court indicated that a Defendant’s right to due process requires that indigency or poverty not be used as the basis for the sentence.

Summary of Case Context & HoldingDefendant was convicted in the district court of two counts of incest. At trial, the jury was deadlocked, and the district court gave a Norquay instruction (adopted in 2011 in Montana to be given to deadlocked juries; State v. Norquay, 248 P.3d 817 (Mont. 2011)). A few days after the conclusion of the trial, a juror contacted the Defendant's attorney and told him that she believed the jury instruction defining "sexual contact" had been misleading. Based on these statements, Defendant filed a post-conviction motion to dismiss, arguing for the first time that the definition of "sexual contact" in the MCA was unconstitutionally vague. Ultimately, the district court denied Defendant's motion to dismiss. It found that Defendant's motion was untimely and that there were no deficiencies in the jury instructions based on the juror’s testimony. After the motion was denied, the district court sentenced Defendant to 100 years imprisonment with 75 years suspended with ineligibility of parole for the first 25 years. Defendant appealed, arguing that (1) the district court was required under the MCA to find by a preponderance of the evidence whether there is an exception to the minimum sentencing guidelines and then to state its reasoning in writing; and (2) that the district court abused its discretion by "prejudg[ing]" his sentence. The Court held that the district court's findings of fact supported Defendant's sentence and its decision not to apply an exception, which did not need to be included in writing in the sentencing order. The Defendant subsequently filed a petition for postconviction relief (PCR), which was denied by the district court. The Supreme Court affirmed the district court's order denying the petition for PCR.

Summary of Case Context & HoldingDefendant appealed his convictions of two homicides and two attempts to solicit a third homicide. One of the questions the Court reviewed on appeal was whether the State's use of jailhouse informants violated Defendant's right to counsel. The Court affirmed the convictions. Detectives told informants they were not being promised any benefits in exchange for information, and neither inmate expected any such benefit. However, one of the jailhouse informants had asked to speak with law enforcement and requested leniency in exchange for providing information, including telling the detective that Defendant solicited him to kill the key witness. A jailhouse informant also shared information about a blood-splattered television in a storage room in the basement, and the detective subsequently applied for a search warrant and gathered more evidence based on information learned from interviews with the jailhouse informants. Defendant argued that the State's use of the jailhouse informants violated his right to counsel by indirectly eliciting incriminating statements from Defendant in the absence of counsel. The Court stated that for Defendant to show the jailhouse informants deliberately elicited incriminating information from him in violation of his right to counsel, he must demonstrate the informants were acting as State agents when they obtained the incriminating information, and that they deliberately elicited that information. The Court held that the State's use of jailhouse informants did not violate Defendant's Sixth Amendment right to counsel, as no facts in the record demonstrated that the jailhouse informants were acting as government agents when they elicited information from Defendant after meeting with detectives. There is no evidence of any agreement, benefit, or instructions, or of any other State actions which transformed the informants into State agents. Accordingly, the court concluded that Defendant's right to counsel was not violated.

Summary of Case Context & HoldingAppellant was convicted of first-degree murder and attempted first-degree murder. On appeal Appellant argued that the district court erred when it overruled his Batson challenge, under Batson v. Kentucky, 476 U.S. 79 (1986), to the State's peremptory strike against a potential juror who had expressed negative feelings toward law enforcement due to the potential juror's race on the grounds that the State responded to the Appellant's argument before the district court determined whether a prima facie case of racial discrimination had been established. The Court held that because it made findings under all prongs of the Batson test, it did not matter that the response to the Appellant's argument occurred before consideration of the existence of a prima facie case of racial discrimination. The Court also held that there was no prima facie case that the strike was made because of the potential juror's race as a result of the fact that (i) an overwhelming number of African-American people have negative feelings toward law enforcement; (ii) the juror's status as a victim of robbery and the friend of a victim of a murder and robbery should have made him an appealing juror to the State; (iii) one of the jurors selected was African-American; and (iv) the stricken juror was questioned no differently than the other jurors.

Summary of Case Context & HoldingDefendant drove his car into an oncoming vehicle while driving in Arizona. A witness driving behind Defendant noted that the car was driving erratically for several miles. After the collision, the witness saw Defendant crawl out of the driver's side of the car. Police on the scene smelled a heavy odor of alcohol from Defendant's car and saw numerous beer cans and an open bottle of liquor. Defendant was airlifted to a hospital in Las Vegas, Nevada. Without seeking a warrant, the police officers, following department policy, requested that Law Vegas police officers collect a blood sample. Defendant was unconscious when the sample was taken. In a matter of first impression the Supreme Court addressed whether the unconscious clause of the implied consent statute, which allows law enforcement to get nonconsensual blood draws from unconscious DUI suspects, was constitutional. The Court held that the provision was unconstitutional as applied to the Defendant and that the law can only be applied when case-specific exigent circumstances prevent officers from obtaining a warrant. The Court also held that, under Arizona law, the good-faith exception, which permits police action if the officers, in good faith, believed a search was permissible, did not apply in this case. The Court remanded to the trial court to determine whether Arizona or Nevada law applied.

Summary of Case Context & HoldingDefendant was convicted of murder and was sentenced to death. Following affirmance by the Supreme Court, Defendant filed a federal petition for a writ of habeas corpus. The District Court of Arizona denied the petition, and Defendant appealed. The Ninth Circuit Court of Appeals remanded the case to federal district court with instructions to grant a writ of habeas corpus, holding that the Supreme Court erred in its independent review of the death sentence when it considered Defendant’s mitigation evidence, which included expert testimony from two mental health professionals attesting to Defendant's emotional and physical abuse as a child, alcohol dependence, and mental impairments. The Supreme Court granted the State’s motion to conduct a new independent review and affirmed the death sentence, holding that the mitigating evidence was not substantial enough to call for leniency in light of the commission of a murder for pecuniary gain and that the Ninth Circuit erred in determining that habeas relief was warranted.

Summary of Case Context & HoldingIn this case, the Supreme Court of Minnesota was required to determine whether the part of Minnesota’s disorderly-conduct statute that prohibits ‘‘disturb[ing]’’ assemblies or meetings, Minn. Stat. § 609.72, subd. 1(2) (2016), is unconstitutional under the First Amendment to the United States Constitution. Both the district court and the court of appeals concluded that the statute is constitutional. However, the Supreme Court of Minnesota reversed, holding that Minn. Stat. § 609.72, subd. 1(2) violates the First Amendment and there is no reasonable narrowing construction of the statute. Appellant was charged with disorderly conduct stemming from her attendance at two city council meetings, where she brought and displayed large signs showing dead and deformed children. In the first meeting, she sat in the gallery (which was allowed). In the second meeting, she took a folding chair and sat in an empty space in front of the gallery, refusing to relocate to the gallery when asked. She was ultimately removed by police and charged with disorderly conduct. Initially, Appellant moved to dismiss the charges, arguing, among other grounds, that the statute in question violated the First Amendment because the language of the statute was unconstitutionally overbroad, unconstitutionally vague, and unconstitutional as applied to her case. With respect to Appellant's claim that the statute was overbroad, the district court agreed, but ultimately upheld the statute by narrowly construing it to require proof that "the disturbance in this case was caused by [Appellant's] conduct itself and not the content of the activity's expression." Appellant was convicted. The court of appeals affirmed the conviction, but disagreed with the district court's analysis of Appellant's overbreadth challenge, instead holding that the disturbance-of-an-assembly-or-meeting statute was a time, place, or manner restriction that was not subject to a standard overbreadth analysis. The Supreme Court of Minnesota reversed, agreeing that the statute was overbroad on its face and that it chilled a "substantial amount of protected speech and expression," because: (i) a statute's plain language is a court's guide to determine the amount of protected speech and expressive conduct regulated by the statute; (ii) the specific statute was not narrowly tailored to serve a significant government interest; (iii) the statute regulated a broad swath of protected speech and expressive conduct, far more than was necessary to maintain order at meetings and assemblies; and (iv) the "negligence standard" covered a wide array of behavior, including actions taken without the intent to disrupt a meeting or assembly.

Summary of Case Context & HoldingHenson was charged with murder, conspiracy, three counts of armed robbery, and five counts of possession of a firearm during the commission of a violent crime. Henson moved for severance of the trial on the grounds that if his co-defendant (jointly tried with him) could present antagonistic defenses, the state would presumably offer the co-defendant's confession as evidence against Henson, and Henson would presumably be prevented from cross-examining the co-defendant about the confession if the co-defendant were to assert the Fifth Amendment. The State opposed severance on the grounds of judicial economy and lack of prejudice. Instead, the State offered to introduce into evidence a redacted confession from the co-defendant and the trial court agreed, denying the motion to sever. The co-defendant did not testify at the trial. Henson was convicted on all charges. The Supreme Court found that the admission of the redacted confession violated the Confrontation Clause of the U.S. Constitution because the jury could infer from the face of the confession that it referred to and incriminated Henson. In so ruling, the Court explained that while severing trials certainly impacts judicial economy and State resources, these factors should not take precedence over the protection of a defendant's constitutional rights. The Court also determined that the violation of the Confrontation Clause was not harmless because the Court could not say that the admission of the co-defendant's testimony did not contribute to the verdict against Henson.

Summary of Case Context & HoldingDefendant was pulled over by officers in a traffic stop that, by the time the car fully came to a stop, was in the Defendant's girlfriend's private driveway. Defendant was found guilty of possession of marijuana, possession of drug paraphernalia, and transporting methamphetamine for sale. Defendant appealed the trial court’s denial of his motion to suppress evidence seized from him and his vehicle. The court of appeals affirmed. The Supreme Court applied its previous decision in State v. Castaneda, 724 P.2d 1 (Ariz. 1986), holding that "[a] third party validly consents to the search” of property when: “(1) the consent is voluntarily given; and (2) the third party has common authority over or other sufficient relationship to the premises or property searched or seized.” The Arizona Supreme Court affirmed, holding (1) the Constitution does not protect a driver that declines to stop on a public road and retreats onto private property; and (2) the officers’ actions in this case comported with Fourth Amendment standards because Defendant impliedly consented to the location of the stop where he led the officers in his vehicle.

Summary of Case Context & HoldingOn the evening of Latrena May's death, May and Defendant, Andre Higgs were arguing outside May's house when an Officer approached them. The Officer testified that Higgs began shooting May shortly after he exited his patrol car. However, Higgs testified that May pulled a gun and he took it from her, and when he tried to surrender to the Officer, the Officer started shooting causing an involuntary discharge of the gun in Higgs's hand. Higgs was convicted of the murder of May and was sentenced to life in prison. Prior to trial, Higgs sought access to the Officer's internal affairs file for information on prior incidents of the Officer firing his weapon on duty. Higgs was denied access by the trial court. At trial, the court granted the State's motion to bar Defendant from questioning the Officer about prior shootings, permitted (despite defense objection) another police officer who was not at the scene to testify about the dashcam footage of the incident, and permitted the State to impeach Defendant using prior indictable convictions for aggravated assault, weapons possession and drug distribution and possession that were 20 and 14 years old because there was a more recent (7 years before trial) disorderly persons charge that was sufficient to bridge the gap. On appeal, the New Jersey Supreme Court considered whether the trial court erred in: (1) prohibiting Defendant from accessing the internal affairs records and prohibiting cross-examination of the Officer about his prior on-duty shootings; (2) allowing the lay opinion testimony of another officer about the dashcam video; and (3) admitting Defendant's prior convictions for impeachment. The Court reversed on all three issues and remanded for a new trial. On the first issue, the Court explained that "for a trial court to grant a motion to conduct an in camera review of an internal affairs file, the defendant must point to a specific category or type of evidence and assert that the evidence, if present in the file, has a relevant nexus to an issue in the case." In this case, the Court reasoned that, because Defendant argued the Officer discharged his firearm first as a theory for his defense, defense counsel should be permitted access to the internal file and should be allowed to explore the Officer’s history of past shootings on cross-examination. On the next issue, because the other officer's testimony was based entirely on his opinion as a layperson (as opposed to an expert witness) and because the video was already in evidence for the jury to evaluate themselves, the officer's testimony was impermissible. Finally, the Court held that the State did not meet its burden of establishing that the probative value of the prior convictions outweighed the prejudicial effect of admitting them.

Summary of Case Context & HoldingThe Supreme Court held that lifetime satellite based monitoring (SBM) based on Defendant's status as an aggravated sex offender was not unconstitutional under the North Carolina State Constitution nor the U.S. Constitution's Fourth Amendment prohibition on unreasonable searches and seizures. In this case the Defendant was an aggravated sex offender because he had sexually assaulted his niece, who was a minor, while he was on probation for other sexual offenses involving children. A trial court ordered the Defendant to enroll in the lifetime SBM program after he pled guilty to first degree statutory rape and sexual offense. When the case reached the Supreme Court, the Supreme Court found that an aggravated sex offenders' expectation of privacy, pursuant to the Fourth Amendment's prohibition on unreasonable searches and seizures, is severely diminished. As a result the Supreme Court found that imposing lifetime SBM on aggravated sex offenders is reasonable and does not violate the Fourth Amendment.

Summary of Case Context & HoldingJuvenile Defendant was convicted as an adult on charges of robbery with use of force, taking and operating a vehicle without the owner's consent, and other charges. Defendant filed a post-conviction motion to vacate the convictions, withdraw his plea, and transfer certain counts back to the juvenile court. Defendant argued that the County's Circuit Court only granted the state's waiver petition to have juveniles tried as an adult on two charges (robbery; and taking and operating a vehicle without owner's consent), not on the remaining charges. However, the Supreme Court held that whenever a juvenile court has previously waived a juvenile who is alleged to be in violation of any state law and who is either convicted or whose criminal proceeding is still pending, courts of criminal jurisdiction anywhere in the state have exclusive original jurisdiction. The dispute between the parties is whether “the court assigned to exercise jurisdiction” i.e., the juvenile court waiving jurisdiction, means only the specific circuit court where the juvenile was waived. For example, would a previous waiver in Milwaukee County Circuit Court confer exclusive original jurisdiction only on the courts of criminal jurisdiction in Milwaukee County? The Supreme Court's interpretation of the statue held that whenever a juvenile court exercising jurisdiction has previously waived a juvenile—who is alleged to be in violation of any state law and that juvenile is either convicted or the criminal proceeding is still pending—courts of criminal jurisdiction anywhere in Wisconsin have exclusive original jurisdiction.

Summary of Case Context & HoldingThe Supreme Court held that the appeals court erred in ruling that Defendant failed to prove purposeful discrimination with respect to the State's use of peremptory challenges to strike jurors at trial. The Supreme Court found that the appellate court erred in reviewing the trial court's completion of a three step analysis for challenging the validity of a peremptory strike under Batson v. Kentucky, 476 U.S. 79 (1986). The first step analysis requires initially that a defendant show a prima facie case for discrimination. The burden then shifts to the State to rebut the evidence. Finally, the third step of the analysis requires the defendant to prove purposeful discrimination. However, the appellate court did not rule on whether the Defendant met his burden under the third step and instead determined that the Defendant did not show a prima facie case of discrimination. The Supreme Court found that when the trial court has already undertaken a Batson analysis, the question of a prima facie case of discrimination becomes moot, so the appellate court must review the trial court's Batson analysis more thoroughly. Moreover, the Supreme Court found that the trial and appeals courts did not adequately consider the evidence offered by the Defendant to support his Batson challenge. The Supreme Court remanded the case to the trial court for a new hearing on the Defendant's Batson claims.

Summary of Case Context & HoldingDefendant was charged with aggravated DUI (which requires a standard DUI plus the existence of certain aggravating factors) and, similar to State v. Zimmerman, 417 P.3d 289 (Mont. 2018), another aggravated DUI case addressing prior DUI convictions, the prosecution sought to introduce Defendant's prior DUI convictions into evidence. The Court noted that, as in Zimmerman, Defendant readily admitted that prior DUIs are an element of the offense of aggravated DUI and merely sought to have the prior DUIs excluded from evidence until the jury determined whether she was driving under the influence on the charge at issue. While the court in Zimmerman suggested that a "bifurcation of trial on Aggravated DUI charges may 'provide a workable solution' to mitigate the prejudice of introducing prior DUI convictions into evidence,'" the court ultimately did not adopt such a rule in Zimmerman. In this case, the Court formally adopted the bifurcation rule and held that the trial should have been bifurcated to cure the unfair prejudice presented by evidence of Defendant's prior DUI convictions. The Court noted that the inherent prejudice of evidence of prior DUI convictions outweighs its probative value until after the jury has determined whether the Defendant was driving under the influence during the specific incident. If the jury finds a defendant guilty of driving under the influence during the first phase of trial, then the state may introduce evidence of prior DUIs to the jury to meet the aggravating element of an aggravated DUI conviction in the second phase of trial. The Court reversed and remanded for new trial.

Summary of Case Context & HoldingPolice responded to a report of a pregnant woman in cardiac arrest. The caller, Appellant, told dispatch that the woman was unconscious, not breathing, and cold. Upon arriving at the scene, police found the woman lying on her back at the bottom of a set of stairs inside the apartment. Officers noticed several red scratches on the left side of Appellant’s face and neck. Appellant claimed he had left to get the woman food, and when he returned home, he found her face down on the floor, wrapped in a blanket, and nonresponsive. While attempting to revive the woman, officers noticed markings, blood, abrasions and bruising on her body. One officer asked Appellant to see the timing of texts from the woman about her desired food order, so that the officer could determine how long the woman had been unresponsive. The officer testified that she did not intend to seize Appellant’s phone at that time but was trying to gain information that might be helpful to the paramedics, and noticed from the timing of texts sent by the victim to the Appellant that the timeframe for her death did not add up. Ultimately the police obtained a warrant to search the phone, his apartment building's surveillance videos and key logs, his body, his apartment, both of his vehicles, multiple electronic devices of the Appellant's, and a variety of computer hardware and documents found in his apartment. The medical examiner determined that the death was caused by another human being, by homicide/strangulation. Appellant was convicted of two counts of first-degree murder for the deaths of his wife and unborn child. On appeal, Appellant raised two arguments. First, the district court erred in admitting evidence from his cell phone, which he contends police illegally seized. Second, the district court erred in admitting evidence obtained from the execution of numerous search warrants, because the warrant applications lacked probable cause. The Supreme Court of Minnesota held that (i) the plain view exception supported the warrantless seizure of Appellant's telephone (because the officers were allowed to consider the context in which the texts were seen in plain view—meaning the timing that the texts were sent versus the story the Appellant had told them); and (ii) probable cause supported the search warrants given the totality of the circumstances, given the officers noticed Appellant's and the victim's injuries and the Appellant's claim as to when the death would have occurred was at odds with the conclusions drawn by the medical examiner.

Summary of Case Context & HoldingThe Supreme Court held that the criminal courts of North Carolina are constitutionally required to open a competency hearing when substantial evidence before the court suggests that Defendant might be incompetent to stand trial under the due process clause. Competency hearings are held to determine if the defendant is capable of standing trial. The Defendant in this case had been convicted of second-degree sexual offense and taking indecent liberties with a child. The trial court did held a competency hearing four months before trial. On the third day of trial, counsel for the Defendant requested that the court re-examine the Defendant's competency. Defense counsel was concerned because the Defendant did not appear to be lucid. The trial court did not hold a second competency hearing. The Supreme Court affirmed the appellate court finding that the trial court committed a prejudicial error by failing to conduct a second competency hearing for the Defendant. The Supreme Court reasoned that competency determinations are an ongoing duty of courts and that competency must be re-evaluated if the evidence changes.

Summary of Case Context & HoldingJerry Charles Holle was convicted by a jury of child molestation and sexual abuse involving a minor under the age of fifteen. The case centered on a statute that made criminal "intentionally or knowingly" touching a child's genitals, anus, or breasts, but provided an affirmative defense to show that the touching was not motivated by a sexual interest. Holle argued that the statute was unconstitutional because it shifted the burden of proof to the defendant to show lack of sexual intent, potentially criminalizing innocent conduct (e.g., non-sexual touching during caregiving). The Court upheld the burden of proof, applying U.S. Supreme Court precedent stating that the Due Process Clause permits states to require criminal defendants to establish a defense by a preponderance, as long as the defense does not negate an element of crime. The dissent argued that the statute was unconstitutionally vague.

Summary of Case Context & HoldingOn August 25, 2020, the Harris County Clerk, Chris Hollins, announced his intention to send ballot-by-mail applications to all eligible voters in the County in advance of the 2020 election, accompanied by educational materials explaining the ballot-by-mail process and detailing the state’s eligibility requirements. On August 31, 2020, the Texas Attorney General sued Chris Hollins, in his official capacity as Harris County Clerk, in an attempt to block Mr. Hollins from moving forward with this plan. The Attorney General argued that the plan exceeded the Harris County Clerk’s statutory authority. On September 11, 2020, the district court denied the Attorney General’s application for a temporary injunction. The same day, the Attorney General filed a notice of accelerated interlocutory appeal. On September 18, 2020, the Fourteenth Court of Appeals affirmed the district court’s denial of the state’s application for a temporary injunction. On October 7, 2020 the Texas Supreme Court reversed the judgment of the court of appeals, holding that Mr. Hollins lacked implied authority under the Election Code to mail unsolicited ballot applications to all registered voters under 65 years of age, only a fraction of whom were eligible to vote by mail. Further, the Court held that the state was entitled to a temporary injunction and that the Texas Election Code does not authorize an “early-voting” county clerk to send an application to vote by mail to a voter who has not requested one. The Court remanded the case to the trial court with orders to enter a temporary injunction against Mr. Hollins.

Summary of Case Context & HoldingAppellant had a troubled marriage with her husband. Both spouses were unfaithful, and Appellant alleged that her husband was physically abusive toward her which lead to several miscarriages. Following a particular incident, Appellant told several close friends (some of whom were her roommates at the time) that her husband had punched her in the stomach, and after some conversation, the group came up with a plan to kill the husband, while staging the killing as a burglary, wherein Appellant's male friend would cut the husband's throat. In exchange, the killer would receive a portion of the soon to be victim's life insurance proceeds. As the plans developed, at the urging of the Appellant, it was decided that the killer would shoot the victim using one of Appellant's guns, at the Appellant's urging. The crime was eventually carried out. Afterward, the Appellant called the police to report the "burglary" but the police became suspicious and ultimately arrested the participants after a questioning session which took place at a police station in an unsecure, unlocked conference room, where the Appellant had not been told she was required to attend the interview, at which Appellant was allowed to leave to use the bathroom, and at which Appellant was never told she was a suspect in the murder. Upon discovering that certain statements given in the session were inconsistent, the investigator seized Appellant's phone without obtaining a warrant. At trial, the district court did not give an accomplice corroboration instruction to the jury with respect to certain testimony given by one of the accomplices who had made a plea deal with the state in exchange for the testimony. At trial, the district court also discovered that one juror was classmates with the aforementioned investigator in fire school years prior. Appellant was arrested on charges of first-degree premeditated murder, and conspiracy to commit first- and second-degree murder, in connection with aiding and abetting another individual in the murder, based in part on certain (unspecified) statements given to police during an interview and (unspecified) data retrieved from Appellant’s phone. Appellant argued first that the statements given in the interview should be inadmissible because the interview took place in custody and Appellant did not receive Miranda warnings. Certain factors are indicative of custody, including (1) the police interviewing the suspect at the police station; (2) the suspect being told he or she is a prime suspect in a crime; (3) the police restraining the suspect's freedom of movement; (4) the suspect making a significantly incriminating statement; (5) the presence of multiple officers; and (6) a gun pointing at the suspect. Certain other factors are indicative of a non-custodial environment: (7) questioning the suspect at home; (8) stating that the suspect is not under arrest; (9) letting the suspect leave the station without hindrance; (10) briefly questioning the suspect; (11) permitting the suspect to leave at any time; (12) conducting the interview in a nonthreatening environment; and (13) allowing the suspect to make phone calls. Because the interview took place at a police station in an unsecure, unlocked conference room, where the Appellant had not been told she was required to attend the interview, at which Appellant was allowed to leave to use the bathroom, and at which Appellant was never told she was a suspect, the Supreme Court of Minnesota held that Appellant was not then "in custody” based on the totality of the circumstances surrounding the interview, and thus was not entitled to Miranda warnings. Appellant argued next that because the investigator seized Appellant's phone without obtaining a warrant, any electronic data retrieved therefrom should have been suppressed. The district court denied a motion to suppress that data. The Supreme Court held that the seizure of Appellant's cell phone was justified by exigent circumstances because data on a cell phone can quickly be destroyed, the seizure was for a limited period of time, the investigator did not know if or when Appellant would terminate the interview, and because warrants take time to obtain. Appellant argued next that the district court erred when it failed to give the accomplice corroboration instruction to the jury, and the Supreme Court held that the failure did not constitute plain error because the district court gave a general witness credibility instruction to the jury, other evidence corroborated the testimony in question, the jury was aware of the accomplice’s plea deal, and the state did not emphasize the testimony of the accomplices over other evidence in its closing argument. Appellant argued finally that the trial court abused its discretion when it denied Appellant’s request to remove the aforementioned juror for cause, and the Supreme Court disagreed because the connection between the investigator and the juror was tenuous (13 years prior, and the two were not close friends), and the juror had stated he could set aside this relationship in making his decision.

Summary of Case Context & HoldingDefendant Terrell Hubbard told a detective that he found his five-month old daughter lying on the bed and noticed she was not breathing. He placed a 911 call and performed CPR while waiting for assistance. Defendant agreed to come to the police station at the detective's request to provide information that might be helpful to medical professionals treating his daughter. Defendant rode in the backseat of the police car to get to the station. While in the interview room, police directed Defendant to a chair so that he was in view of the camera and asked probing questions about his feelings about his daughter and his treatment of her. Defendant did not admit to anything in the initial interview, but was in the police station for a total of three hours. During that time, Miranda warnings were never administered to him. The daughter later died in the hospital. The medical examiner noted the daughter had bruises, fractures, and broken bones. Defendant later admitted to tossing the baby toward the bed causing her to hit the wall and stop breathing. A grand jury returned an indictment charging Defendant with second-degree manslaughter and second-degree endangering the welfare of a child. The trial court granted Defendant's motion to suppress his statements to the detective during the initial interview by finding that he was in custody at the time of the statements but had not been advised of his Miranda rights. The Appellate Division granted the State's motion for leave to appeal and reversed, based on the grounds that the New Jersey Supreme Court's ruling in State v. Diaz-Bridges, 34 A.3d 748 (N.J. 2012) permitted the court to conduct a de novo review of the trial record without deferring to the findings of fact and credibility assessments of the trial court, because it concluded that the trial court had based its findings of fact solely on the videotape of the detective's interview. The appellate court found that Defendant had not been subject to a custodial interrogation and therefore, the failure to administer Miranda warnings did not require suppression of the statements. The Supreme Court reversed finding that the interview conducted by the detective at the police station was a custodial interrogation and the failure to administer Miranda warnings prior to the interview required suppression of that recorded statement.

Summary of Case Context & HoldingThe prosecutor insinuated during closing arguments at trial that the "[D]efendant was a liar and lied on the stand in cahoots with defense counsel and his expert witness." The court of appeals found that these insinuations resulted in unfair prejudice to the Defendant because of their cumulative impact. A new trial was ordered. The Supreme Court agreed that the prosecutor's comments at closing arguments were improper. However, the Supreme Court held that the statements were not so grossly improper as to violate the Defendant's due process rights because the jury verdict convicted Defendant for a lesser included offense. The lesser conviction indicated that the jury believed the testimony of the Defendant and expert witness to some degree. As a result, the Supreme Court reasoned that the prosecutors insinuations about the Defendant being in cahoots with the defense counsel and expert witness did not result in unfair prejudice.