State Supreme Court Data Tracker
Use this data to spot trends, anticipate what’s next, and supercharge your advocacy.
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State v. McQueen, 256 A.3d 966 (N.J. 2021)
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New Jersey | 2021 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2021
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was arrested after driving off when police officers attempted to stop him for traffic violations. Defendant made a phone call later that day at police headquarters which was recorded by police unbeknownst to him. Later, police recovered a gun found outside the home where Defendant had been stopped and became suspicious about the call Defendant had made from headquarters. The police then listened to Defendant's recorded conversation, which revealed that Defendant had discussed the gun on the phone call. Defendant was indicted and moved to suppress the telephone conversations. The trial court suppressed the recorded calls. The Appellate Division reversed the suppression. The issue before the Supreme Court was whether Defendant's custodial status in the station house meant the police needed a warrant to seize the telephone conversation. The Supreme Court held that an arrestee has a reasonable expectation of privacy in a call made from a police station in the absence of notice that the conversation may be monitored or recorded. Therefore, the Supreme Court concluded that police needed a warrant to listen to the recorded call absent consent and the conversation should have been suppressed.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was arrested after driving off when police officers attempted to stop him for traffic violations. Defendant made a phone call later that day at police headquarters which was recorded by police unbeknownst to him. Later, police recovered a gun found outside the home where Defendant had been stopped and became suspicious about the call Defendant had made from headquarters. The police then listened to Defendant's recorded conversation, which revealed that Defendant had discussed the gun on the phone call. Defendant was indicted and moved to suppress the telephone conversations. The trial court suppressed the recorded calls. The Appellate Division reversed the suppression. The issue before the Supreme Court was whether Defendant's custodial status in the station house meant the police needed a warrant to seize the telephone conversation. The Supreme Court held that an arrestee has a reasonable expectation of privacy in a call made from a police station in the absence of notice that the conversation may be monitored or recorded. Therefore, the Supreme Court concluded that police needed a warrant to listen to the recorded call absent consent and the conversation should have been suppressed.
Link to Opinion
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State v. McQueen, 828 N.W.2d 644 (Mich. 2013)
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Michigan | 2013 | Criminal Justice |
State:
Michigan
Year:
2013
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Michigan Medical Marihuana Act (MMMA) authorizes and immunizes the medical use of marijuana. Here, Defendants owned a business connecting qualifying patients who had excess marijuana with qualifying caregivers who needed marijuana for sale transactions. The MMMA defines "medical use" to “include the transfer of marijuana to treat or alleviate a registered qualifying patient’s debilitating medical condition or symptoms.” The Supreme Court reversed the court of appeals holding that the “transfer” within the MMMA’s definition includes the sale of marijuana. Nonetheless, the Supreme Court determined that Defendants' conduct was not covered by the Act’s immunity provision. MMMA’s immunity provision creates a rebuttable presumption of medical use that can be overcome by evidence that the conduct in question was for a purpose other than alleviating the qualifying patient’s condition. Here, the Supreme Court held that using the marijuana of one qualifying patient to alleviate the condition of another qualifying patient is a purpose that overcomes the rebuttable presumption of immunity. Thus, Defendant’s business served purposes other than those granted immunity under the MMMA.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Michigan Medical Marihuana Act (MMMA) authorizes and immunizes the medical use of marijuana. Here, Defendants owned a business connecting qualifying patients who had excess marijuana with qualifying caregivers who needed marijuana for sale transactions. The MMMA defines "medical use" to “include the transfer of marijuana to treat or alleviate a registered qualifying patient’s debilitating medical condition or symptoms.” The Supreme Court reversed the court of appeals holding that the “transfer” within the MMMA’s definition includes the sale of marijuana. Nonetheless, the Supreme Court determined that Defendants' conduct was not covered by the Act’s immunity provision. MMMA’s immunity provision creates a rebuttable presumption of medical use that can be overcome by evidence that the conduct in question was for a purpose other than alleviating the qualifying patient’s condition. Here, the Supreme Court held that using the marijuana of one qualifying patient to alleviate the condition of another qualifying patient is a purpose that overcomes the rebuttable presumption of immunity. Thus, Defendant’s business served purposes other than those granted immunity under the MMMA.
Link to Opinion
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State v. McQueen, 828 N.W.2d 644 (Mich. 2013)
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Michigan | 2013 | Health Care, Public Health |
State:
Michigan
Year:
2013
Topics:
Health Care, Public Health
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendants owned and operated a members-only medical marijuana dispensary that conducted patient-to-patient sales of marijuana. The State sought to enjoin their sale of marijuana, alleging that the business constituted a public nuisance because it did not comply with the Michigan Medical Marihuana Act (MMMA). The trial court denied a request for a preliminary injunction, but the court of appeals reversed and remanded the case. The dispensary sought review. On review, the Supreme Court concluded that the dispensary did not comply with the MMMA but affirmed the court of appeals' decision on alternative grounds. The Supreme Court held that although the sale of marijuana constitutes "medical use" under MCL 333.26423(e), Section 4 of the MMMA (the immunity provision) does not permit a registered qualifying patient to transfer marijuana for another such patient's use, and Section 8 of the MMMA (affirmative defense) applies only to criminal prosecutions. As a result, the State was entitled to injunctive relief for the dispensary's violation of the Public Health Code.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendants owned and operated a members-only medical marijuana dispensary that conducted patient-to-patient sales of marijuana. The State sought to enjoin their sale of marijuana, alleging that the business constituted a public nuisance because it did not comply with the Michigan Medical Marihuana Act (MMMA). The trial court denied a request for a preliminary injunction, but the court of appeals reversed and remanded the case. The dispensary sought review. On review, the Supreme Court concluded that the dispensary did not comply with the MMMA but affirmed the court of appeals' decision on alternative grounds. The Supreme Court held that although the sale of marijuana constitutes "medical use" under MCL 333.26423(e), Section 4 of the MMMA (the immunity provision) does not permit a registered qualifying patient to transfer marijuana for another such patient's use, and Section 8 of the MMMA (affirmative defense) applies only to criminal prosecutions. As a result, the State was entitled to injunctive relief for the dispensary's violation of the Public Health Code.
Link to Opinion
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State v. Melendez, 565 P.3d 1034 (Ariz. 2025)
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Arizona | 2025 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2025
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingMelendez was taken into police custody after shooting a gun at an individual. After hearing his Miranda rights, Defendant said he no longer wanted to talk and the interview ended. Five hours later, a detective interviewed Defendant after re-reading him his Miranda rights and confirming Defendant understood. Defendant willingly continued with the interview but deferred answering some questions. After a break, Defendant volunteered his version of the events to the detective, answering some questions he passed on earlier, including that he shot at the person due to perceived aggression. At trial, Defendant testified that he fired in self-defense because he thought the person was going to shoot him. On cross-examination, the prosecutor attempted to impeach Defendant by saying that he passed on many answers in his interview and only asserted self-defense after the detective told him he was going to jail. The prosecutor then urged the jury to question the credibility of the self-defense claim because a reasonable person would have answered questions if they really shot in self-defense. Defendant was convicted on all charges. On appeal, the Court addressed whether a State violates a defendant’s due process rights under the Fourteenth Amendment of the U.S. Constitution when, for impeachment purposes, it comments on a defendant’s post-Miranda statements and deferral of responses when answering questions in custody. The Court held that the State may use such statements, and lack of statements, for impeachment purposes if the defendant fails to unambiguously invoke his Miranda rights and speaks on substantive matters. Therefore, the Court held the State did not violate the Defendant’s due process rights and affirmed the conviction and sentence. The Court reasoned that while prosecutors generally cannot comment on the post-invocation of the right to remain silent, here, Defendant chose to continue the second interview meaning he did not invoke his right to remain silent in the second interview, elected to delay his responses, and ultimately answered substantive questions. He deferred responses to later in the interview, but was not selectively silent. The Court explained the prosecutor’s actions were akin to regular impeachment because the prosecutor was contrasting different self-defense statements to impeach, not relying on Defendant’s silence.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Melendez was taken into police custody after shooting a gun at an individual. After hearing his Miranda rights, Defendant said he no longer wanted to talk and the interview ended. Five hours later, a detective interviewed Defendant after re-reading him his Miranda rights and confirming Defendant understood. Defendant willingly continued with the interview but deferred answering some questions. After a break, Defendant volunteered his version of the events to the detective, answering some questions he passed on earlier, including that he shot at the person due to perceived aggression. At trial, Defendant testified that he fired in self-defense because he thought the person was going to shoot him. On cross-examination, the prosecutor attempted to impeach Defendant by saying that he passed on many answers in his interview and only asserted self-defense after the detective told him he was going to jail. The prosecutor then urged the jury to question the credibility of the self-defense claim because a reasonable person would have answered questions if they really shot in self-defense. Defendant was convicted on all charges. On appeal, the Court addressed whether a State violates a defendant’s due process rights under the Fourteenth Amendment of the U.S. Constitution when, for impeachment purposes, it comments on a defendant’s post-Miranda statements and deferral of responses when answering questions in custody. The Court held that the State may use such statements, and lack of statements, for impeachment purposes if the defendant fails to unambiguously invoke his Miranda rights and speaks on substantive matters. Therefore, the Court held the State did not violate the Defendant’s due process rights and affirmed the conviction and sentence. The Court reasoned that while prosecutors generally cannot comment on the post-invocation of the right to remain silent, here, Defendant chose to continue the second interview meaning he did not invoke his right to remain silent in the second interview, elected to delay his responses, and ultimately answered substantive questions. He deferred responses to later in the interview, but was not selectively silent. The Court explained the prosecutor’s actions were akin to regular impeachment because the prosecutor was contrasting different self-defense statements to impeach, not relying on Defendant’s silence.
Link to Opinion
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State v. Melvin, 258 A.3d 1075 (N.J.2021)
State v. Paden-Battle, 258 A.3d 1075 (N.J. 2021)
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New Jersey | 2021 | Criminal Justice, Access to Justice |
State:
New Jersey
Year:
2021
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingMelvin was convicted of unlawful possession of a handgun but acquitted of other charges, including murder. When the trial court sentenced Melvin on the weapons charge, it imposed the maximum sentence, citing evidence related to the murder charge to enhance Melvin's sentence. The Appellate Division affirmed Melvin's conviction but remanded for resentencing because it found that the judge had substituted his judgment for that of the jury by claiming (contrary to the jury's decision) that Melvin had committed a shooting, and considering that behavior in Melvin's sentencing. On remand, the same trial judge again imposed an extended sentence based on the conduct related to the murder charge. Paden-Battle was convicted of kidnapping, conspiracy to commit kidnapping, and felony murder, and acquitted of first-degree murder, conspiracy to commit murder, and weapons offenses. For the felony murder conviction, the trial court gave Paden-Battle a sentence of twice the statutory minimum, based on claims that Paden-Battle was the "mastermind" and "the driving force in this kidnapping and execution," despite her acquittal of the first degree murder and conspiracy to commit murder charges. The Supreme Court considered Paden-Battle's case in conjunction with Melvin's, analyzing the cases together. In both cases, the issue presented to the New Jersey Supreme Court was whether a trial judge can consider at sentencing a defendant's alleged conduct for crimes for which the jury returned a not guilty verdict. The Supreme Court held that acquitted conduct cannot be considered to enhance a sentence. The Supreme Court rejected the idea that the facts of a criminal case could be re-litigated under a lower evidentiary standard, for the reason that this would place the finality of a not-guilty jury verdict in question and allow judicial fact-finding to ignore the jury's verdict at sentencing. The Supreme Court therefore reversed the judgment of the Appellate Division in Melvin and remanded for resentencing, and affirmed the decision of the Appellate Division in Paden-Battle that vacated the sentence and remanded for resentencing.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Melvin was convicted of unlawful possession of a handgun but acquitted of other charges, including murder. When the trial court sentenced Melvin on the weapons charge, it imposed the maximum sentence, citing evidence related to the murder charge to enhance Melvin's sentence. The Appellate Division affirmed Melvin's conviction but remanded for resentencing because it found that the judge had substituted his judgment for that of the jury by claiming (contrary to the jury's decision) that Melvin had committed a shooting, and considering that behavior in Melvin's sentencing. On remand, the same trial judge again imposed an extended sentence based on the conduct related to the murder charge. Paden-Battle was convicted of kidnapping, conspiracy to commit kidnapping, and felony murder, and acquitted of first-degree murder, conspiracy to commit murder, and weapons offenses. For the felony murder conviction, the trial court gave Paden-Battle a sentence of twice the statutory minimum, based on claims that Paden-Battle was the "mastermind" and "the driving force in this kidnapping and execution," despite her acquittal of the first degree murder and conspiracy to commit murder charges. The Supreme Court considered Paden-Battle's case in conjunction with Melvin's, analyzing the cases together. In both cases, the issue presented to the New Jersey Supreme Court was whether a trial judge can consider at sentencing a defendant's alleged conduct for crimes for which the jury returned a not guilty verdict. The Supreme Court held that acquitted conduct cannot be considered to enhance a sentence. The Supreme Court rejected the idea that the facts of a criminal case could be re-litigated under a lower evidentiary standard, for the reason that this would place the finality of a not-guilty jury verdict in question and allow judicial fact-finding to ignore the jury's verdict at sentencing. The Supreme Court therefore reversed the judgment of the Appellate Division in Melvin and remanded for resentencing, and affirmed the decision of the Appellate Division in Paden-Battle that vacated the sentence and remanded for resentencing.
Link to Opinion
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State v. Mercier, 479 P.3d 967 (Mont. 2021)
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Montana | 2021 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2021
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant appealed his conviction of deliberate homicide, arguing that the trial court erred in allowing a special agent to testify via two-way video-conferencing. The Court summarized earlier case findings that the purpose of the Confrontation Clause is "ensure[ing] reliability of the evidence against a criminal defendant by subjecting it to rigorous testing in the context of an adversary proceeding," a purpose that is fulfilled by "guarantee[ing] the defendant a face-to-face meeting with witnesses appearing before the trier of fact." Maryland v. Craig, 497 U.S. 836, 844 (1990), quoting Coy v. Iowa, 487 U.S. 1012, 1016 (1988). The Court discussed the two-prong Craig analysis which requires (1) showing that denial of physical face-to-face confrontation is necessary to further an important public policy; and (2) determining that reliability of the testimony is otherwise assured. The Court noted that to satisfy Craig's second reliability prong, the hallmarks of confrontation must be present. In particular, the non-physically present witness must be under oath and understand the seriousness of his or her testimony, be subject to cross-examination, and permit assessment of the witness's veracity by the factfinder. The Court stated that although judicial economy may be an important public policy in other contexts, standing alone, it must yield to the constitutional rights of the accused. The Court held in this case that furtherance of an important public policy to allow the special agent to testify via two-way videoconferencing was not demonstrated, and accordingly the first prong of the Craig analysis was not satisfied. The Court therefore concluded that Defendant's right of confrontation was violated. The Court further concluded that the State did not demonstrate the that Confrontation Clause error was harmless, requiring reversal of one of Defendant's convictions.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant appealed his conviction of deliberate homicide, arguing that the trial court erred in allowing a special agent to testify via two-way video-conferencing. The Court summarized earlier case findings that the purpose of the Confrontation Clause is "ensure[ing] reliability of the evidence against a criminal defendant by subjecting it to rigorous testing in the context of an adversary proceeding," a purpose that is fulfilled by "guarantee[ing] the defendant a face-to-face meeting with witnesses appearing before the trier of fact." Maryland v. Craig, 497 U.S. 836, 844 (1990), quoting Coy v. Iowa, 487 U.S. 1012, 1016 (1988). The Court discussed the two-prong Craig analysis which requires (1) showing that denial of physical face-to-face confrontation is necessary to further an important public policy; and (2) determining that reliability of the testimony is otherwise assured. The Court noted that to satisfy Craig's second reliability prong, the hallmarks of confrontation must be present. In particular, the non-physically present witness must be under oath and understand the seriousness of his or her testimony, be subject to cross-examination, and permit assessment of the witness's veracity by the factfinder. The Court stated that although judicial economy may be an important public policy in other contexts, standing alone, it must yield to the constitutional rights of the accused. The Court held in this case that furtherance of an important public policy to allow the special agent to testify via two-way videoconferencing was not demonstrated, and accordingly the first prong of the Craig analysis was not satisfied. The Court therefore concluded that Defendant's right of confrontation was violated. The Court further concluded that the State did not demonstrate the that Confrontation Clause error was harmless, requiring reversal of one of Defendant's convictions.
Link to Opinion
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State v. Michel, 257 So. 3d 3 (Fla. 2018)
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Florida | 2018 | Criminal Justice, Juvenile Justice |
State:
Florida
Year:
2018
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingMichel, who was sixteen years old when the crimes were committed, was charged with first-degree murder and sentenced to life in prison with the possibility of parole after twenty-five years. After the U.S. Supreme Court issued its opinion in Miller v. Alabama, 567 U.S. 460 (2012) (holding that mandatory sentences of life without the possibility of parole are unconstitutional for juvenile offenders), Michel filed a motion for postconviction relief. The motion asserted that Michel was sentenced to life in prison for a homicide and, because he was under eighteen at the time of the crime, he was entitled to relief under Miller. The State argued that Miller was inapplicable because Michel had the opportunity for release on parole. The trial court summarily denied the motion. On appeal, the Fourth District reversed, interpreting the Florida Supreme Court's opinion in Atwell v. State, 197 So. 3d 1040 (Fla. 2016), to require resentencing even where the offender may later obtain parole. The Florida Supreme Court determined that the more recent U.S. Supreme Court decision of Virginia v. LeBlanc, 582 U.S. 91 (2017) (confirming that a juvenile offender’s sentence of life for a nonhomicide crime subject to the possibility of conditional geriatric release was not an unreasonable application of the Supreme Court’s case law), has clarified that the majority’s holding in Atwell does not properly apply United States Supreme Court precedent. Finding that Florida's parole system provides juveniles with a meaningful opportunity to receive parole, the Florida Supreme Court held that a juvenile offender's sentence of life with the possibility of parole after 25 years does not violate the Eighth Amendment of the U.S. Constitution as delineated by the U.S. Supreme Court in Graham v. Florida, 560 U.S. 48 (2010), Miller v. Alabama, 567 U.S. 460 (2012), and Virginia v. LeBlanc. Therefore, such juvenile offenders are not entitled to resentencing.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Michel, who was sixteen years old when the crimes were committed, was charged with first-degree murder and sentenced to life in prison with the possibility of parole after twenty-five years. After the U.S. Supreme Court issued its opinion in Miller v. Alabama, 567 U.S. 460 (2012) (holding that mandatory sentences of life without the possibility of parole are unconstitutional for juvenile offenders), Michel filed a motion for postconviction relief. The motion asserted that Michel was sentenced to life in prison for a homicide and, because he was under eighteen at the time of the crime, he was entitled to relief under Miller. The State argued that Miller was inapplicable because Michel had the opportunity for release on parole. The trial court summarily denied the motion. On appeal, the Fourth District reversed, interpreting the Florida Supreme Court's opinion in Atwell v. State, 197 So. 3d 1040 (Fla. 2016), to require resentencing even where the offender may later obtain parole. The Florida Supreme Court determined that the more recent U.S. Supreme Court decision of Virginia v. LeBlanc, 582 U.S. 91 (2017) (confirming that a juvenile offender’s sentence of life for a nonhomicide crime subject to the possibility of conditional geriatric release was not an unreasonable application of the Supreme Court’s case law), has clarified that the majority’s holding in Atwell does not properly apply United States Supreme Court precedent. Finding that Florida's parole system provides juveniles with a meaningful opportunity to receive parole, the Florida Supreme Court held that a juvenile offender's sentence of life with the possibility of parole after 25 years does not violate the Eighth Amendment of the U.S. Constitution as delineated by the U.S. Supreme Court in Graham v. Florida, 560 U.S. 48 (2010), Miller v. Alabama, 567 U.S. 460 (2012), and Virginia v. LeBlanc. Therefore, such juvenile offenders are not entitled to resentencing.
Link to Opinion
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State v. Miles, 160 A.3d 23 (N.J. 2017)
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New Jersey | 2017 | Criminal Justice |
State:
New Jersey
Year:
2017
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was charged in a warrant complaint with two charges of possession of marijuana, including a charge for possession on or within 1000 feet of school grounds. In a separate municipal summons, Defendant was also charged with a disorderly persons offense for possession of marijuana that was later amended to a different possession charge: loitering to possess marijuana. The charges all arose from the same attempted sale. At municipal court, Defendant pled guilty. Defendant then moved to dismiss the superior court indictment on double-jeopardy grounds, arguing that prosecution was barred because he pled guilty to an offense that arose from the same conduct. The superior court denied Defendant's motion to dismiss, reasoning that the indictment was not barred because it required proof of an additional element--proximity to a school. The Appellate Division was divided as to whether to use the same elements test or the same evidence test to determine whether two offenses are the same for double-jeopardy purposes. The State appealed. Joining the majority of jurisdictions, the New Jersey Supreme Court held that the "Blockburger same-elements test" is the sole test to be used to determine what constitutes the same offense for purposes of double jeopardy. Under Blockburger v. United States, 284 U.S. 299 (1932), "where the same act or transaction constitutes a violation of two distinct statutory provisions, the test to be applied to determine whether there are two offenses or only one, is whether each provision requires proof of a fact which the other does not." Although the decision applied to all cases going forward, in fairness to the Defendant, the Court applied both tests to Defendant's conduct to reflect the legal landscape at the time he was charged, and found that under the same-evidence test, loitering was the same offense as the school-zone offense, and thus successive prosecution for the school-zone offense was barred by double jeopardy.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was charged in a warrant complaint with two charges of possession of marijuana, including a charge for possession on or within 1000 feet of school grounds. In a separate municipal summons, Defendant was also charged with a disorderly persons offense for possession of marijuana that was later amended to a different possession charge: loitering to possess marijuana. The charges all arose from the same attempted sale. At municipal court, Defendant pled guilty. Defendant then moved to dismiss the superior court indictment on double-jeopardy grounds, arguing that prosecution was barred because he pled guilty to an offense that arose from the same conduct. The superior court denied Defendant's motion to dismiss, reasoning that the indictment was not barred because it required proof of an additional element--proximity to a school. The Appellate Division was divided as to whether to use the same elements test or the same evidence test to determine whether two offenses are the same for double-jeopardy purposes. The State appealed. Joining the majority of jurisdictions, the New Jersey Supreme Court held that the "Blockburger same-elements test" is the sole test to be used to determine what constitutes the same offense for purposes of double jeopardy. Under Blockburger v. United States, 284 U.S. 299 (1932), "where the same act or transaction constitutes a violation of two distinct statutory provisions, the test to be applied to determine whether there are two offenses or only one, is whether each provision requires proof of a fact which the other does not." Although the decision applied to all cases going forward, in fairness to the Defendant, the Court applied both tests to Defendant's conduct to reflect the legal landscape at the time he was charged, and found that under the same-evidence test, loitering was the same offense as the school-zone offense, and thus successive prosecution for the school-zone offense was barred by double jeopardy.
Link to Opinion
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State v. Miles, 414 P.3d 680 (Ariz. 2018)
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Arizona | 2018 | Criminal Justice, Death Penalty |
State:
Arizona
Year:
2018
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of first-degree murder, dangerous kidnapping, and dangerous armed robbery, and was sentenced to death. Defendant appealed and the Arizona Supreme Court affirmed, finding that Defendant was a major participant in the crimes and had shown reckless indifference toward human life. After the denial of his request for postconviction relief (PCR), Defendant petitioned for habeas corpus relief in federal court. The District of Arizona denied relief. Defendant appealed, and on rehearing, the court of appeals affirmed. Defendant then initiated a second PCR proceeding. The Superior Court of Pima County granted Defendant relief by commuting his death sentence to a life sentence, holding (1) Defendant was ineligible for the death penalty because reasonable doubt existed as to whether he acted with the requisite reckless mental state; and (2) even if Defendant was death-eligible, he would be entitled to resentencing because he sufficiently demonstrated that the sentencing court would not have imposed the death penalty had it known of his mental health deficiencies. The State petitioned for review, which was granted. The Supreme Court affirmed the ruling that Defendant was ineligible for the death penalty because reasonable doubt existed whether he acted with the requisite reckless mental state and remanded the case due to newly proffered mitigation evidence and consequently held that the superior court did not err by admitting diminished-capacity and voluntary-intoxication evidence.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of first-degree murder, dangerous kidnapping, and dangerous armed robbery, and was sentenced to death. Defendant appealed and the Arizona Supreme Court affirmed, finding that Defendant was a major participant in the crimes and had shown reckless indifference toward human life. After the denial of his request for postconviction relief (PCR), Defendant petitioned for habeas corpus relief in federal court. The District of Arizona denied relief. Defendant appealed, and on rehearing, the court of appeals affirmed. Defendant then initiated a second PCR proceeding. The Superior Court of Pima County granted Defendant relief by commuting his death sentence to a life sentence, holding (1) Defendant was ineligible for the death penalty because reasonable doubt existed as to whether he acted with the requisite reckless mental state; and (2) even if Defendant was death-eligible, he would be entitled to resentencing because he sufficiently demonstrated that the sentencing court would not have imposed the death penalty had it known of his mental health deficiencies. The State petitioned for review, which was granted. The Supreme Court affirmed the ruling that Defendant was ineligible for the death penalty because reasonable doubt existed whether he acted with the requisite reckless mental state and remanded the case due to newly proffered mitigation evidence and consequently held that the superior court did not err by admitting diminished-capacity and voluntary-intoxication evidence.
Link to Opinion
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State v. Miller, 510 P.3d 17 (Mont. 2022)
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Montana | 2022 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2022
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant, a black man, was found guilty by an all white jury of assault, misdemeanor possession of marijuana, and misdemeanor possession of drug paraphernalia. Defendant was sentenced to nine years in prison for assault with a weapon. During jury voir dire at the beginning of the trial, the only non-white juror stated that, based on a multitude of personal experiences with racial discrimination in the community, she had concerns about being a juror on a case involving a black defendant. The Court considered the issue of whether the district court erroneously allowed the State to peremptorily strike the only non-white member of the jury based on her statements. The Court noted that under the second prong of Batson v. Kentucky, 476 U.S. 79 (1986) (case holding that a defendant may establish a prima facie case of purposeful discrimination in selection of the jury solely based on evidence concerning the prosecutor's exercise of peremptory challenges at the defendant's trial), the striking party must state a case-specific race-neutral explanation that may not be based on a party's assumption or intuition that the prospective jury would favor the challenging party based on their shared race. The Court held that the State's peremptory strike of the prospective juror was not plain error under the three-prong Batson equal protection analysis because the juror made statements that she could not be fair due to her personal experiences with racial discrimination. The juror's initial and supplemental verbal and non-verbal voir dire responses directly supported the State's race-neutral explanation for striking her, as distinct from the juror's non-race-neutral explanation for why she could not be fair. The Court also found that the Defendant failed to show that the peremptory strike resulted in a manifest miscarriage of justice or otherwise prejudicially undermined the fundamental fairness of the trial or compromised the integrity of the judicial process.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant, a black man, was found guilty by an all white jury of assault, misdemeanor possession of marijuana, and misdemeanor possession of drug paraphernalia. Defendant was sentenced to nine years in prison for assault with a weapon. During jury voir dire at the beginning of the trial, the only non-white juror stated that, based on a multitude of personal experiences with racial discrimination in the community, she had concerns about being a juror on a case involving a black defendant. The Court considered the issue of whether the district court erroneously allowed the State to peremptorily strike the only non-white member of the jury based on her statements. The Court noted that under the second prong of Batson v. Kentucky, 476 U.S. 79 (1986) (case holding that a defendant may establish a prima facie case of purposeful discrimination in selection of the jury solely based on evidence concerning the prosecutor's exercise of peremptory challenges at the defendant's trial), the striking party must state a case-specific race-neutral explanation that may not be based on a party's assumption or intuition that the prospective jury would favor the challenging party based on their shared race. The Court held that the State's peremptory strike of the prospective juror was not plain error under the three-prong Batson equal protection analysis because the juror made statements that she could not be fair due to her personal experiences with racial discrimination. The juror's initial and supplemental verbal and non-verbal voir dire responses directly supported the State's race-neutral explanation for striking her, as distinct from the juror's non-race-neutral explanation for why she could not be fair. The Court also found that the Defendant failed to show that the peremptory strike resulted in a manifest miscarriage of justice or otherwise prejudicially undermined the fundamental fairness of the trial or compromised the integrity of the judicial process.
Link to Opinion
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State v. Miller, 800 S.E.2d 400 (N.C. 2017)
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North Carolina | 2017 | Criminal Justice |
State:
North Carolina
Year:
2017
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn this case Defendant was convicted under a new statute. The statute created a strict liability offense for when a person previously convicted of possessing methamphetamine possesses a product containing pseudoephedrine. Pseudoephedrine is in many over the counter drugs and can be used to treat nasal congestion. But it can also be used to cook methamphetamine. The court of appeals overturned the conviction, holding that the statute was unconstitutional on due process grounds as applied to the Defendant. Specifically, since the possession of products containing pseudoephedrine is generally legal, the appeals court found that there was no reason for the Defendant to have inquired into whether the law regarding his possession of the drug changed. In addition, the Defendant lacked notice that "an innocent act previously legal for him" had been transformed into a felony. The Supreme Court reversed the appellate court's decision, holding that there was no due process violation because the conviction did not rest on a "wholly passive" failure to act by the Defendant. The Supreme Court noted that the Defendant actively purchased a product with pseudoephedrine after the law changed and was aware that he possessed the product. Because the Defendant's conduct that lead to conviction was active, rather than passive, the court found no need to inquire into whether Defendant had notice of the law and decided that as such there was no due process violation.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In this case Defendant was convicted under a new statute. The statute created a strict liability offense for when a person previously convicted of possessing methamphetamine possesses a product containing pseudoephedrine. Pseudoephedrine is in many over the counter drugs and can be used to treat nasal congestion. But it can also be used to cook methamphetamine. The court of appeals overturned the conviction, holding that the statute was unconstitutional on due process grounds as applied to the Defendant. Specifically, since the possession of products containing pseudoephedrine is generally legal, the appeals court found that there was no reason for the Defendant to have inquired into whether the law regarding his possession of the drug changed. In addition, the Defendant lacked notice that "an innocent act previously legal for him" had been transformed into a felony. The Supreme Court reversed the appellate court's decision, holding that there was no due process violation because the conviction did not rest on a "wholly passive" failure to act by the Defendant. The Supreme Court noted that the Defendant actively purchased a product with pseudoephedrine after the law changed and was aware that he possessed the product. Because the Defendant's conduct that lead to conviction was active, rather than passive, the court found no need to inquire into whether Defendant had notice of the law and decided that as such there was no due process violation.
Link to Opinion
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State v. Miller, 800 S.E.2d 400 (N.C. 2017)
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North Carolina | 2017 | Health Care, Health Care Access/Funding, Health Care Discrimination |
State:
North Carolina
Year:
2017
Topics:
Health Care, Health Care Access/Funding, Health Care Discrimination
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 2013, the North Carolina General Assembly made it unlawful for any person to possess a pseudoephedrine product if that person has a prior conviction for the possession or manufacture of methamphetamine. Here, the Defendant argued his due process rights under the U.S. Constitution were violated on the grounds that, when a state has subjected otherwise innocent and lawful behavior to significant penalties, due process considerations require either scienter (intent) or mens rea to be shown to prove guilt, or alternatively, that the state must establish that the Defendant had a fair warning the previously lawful act would not be subject to criminal punishment. The Supreme Court held that the conviction did not violate the Defendant's constitutional rights, since it rested on the Defendant's own active conduct rather than a "wholly passive" failure to act.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 2013, the North Carolina General Assembly made it unlawful for any person to possess a pseudoephedrine product if that person has a prior conviction for the possession or manufacture of methamphetamine. Here, the Defendant argued his due process rights under the U.S. Constitution were violated on the grounds that, when a state has subjected otherwise innocent and lawful behavior to significant penalties, due process considerations require either scienter (intent) or mens rea to be shown to prove guilt, or alternatively, that the state must establish that the Defendant had a fair warning the previously lawful act would not be subject to criminal punishment. The Supreme Court held that the conviction did not violate the Defendant's constitutional rights, since it rested on the Defendant's own active conduct rather than a "wholly passive" failure to act.
Link to Opinion
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State v. Miller, 814 S.E.2d 81 (N.C. 2018)
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North Carolina | 2018 | Criminal Justice |
State:
North Carolina
Year:
2018
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant who was found in possession of cocaine did not move to suppress evidence of the cocaine at trial. Nonetheless, the Defendant sought to argue on appeal that the drugs' seizure resulted from Fourth Amendment violations. The court of appeals found that the trial court committed plain error by admitting evidence of the cocaine. To find plain error an appellate court must find that a "fundamental" error occurred at trial. Fundamental means that the error likely impacted the jury finding the Defendant guilty and seriously affected the "fairness, integrity, or public reputation of judicial proceedings." The Supreme Court overturned the appellate court's findings. The Supreme Court held that the "[D]efendant’s Fourth Amendment claims were not reviewable on direct appeal, even for plain error, because he completely waived them by not moving to suppress evidence of the cocaine before or at trial."
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant who was found in possession of cocaine did not move to suppress evidence of the cocaine at trial. Nonetheless, the Defendant sought to argue on appeal that the drugs' seizure resulted from Fourth Amendment violations. The court of appeals found that the trial court committed plain error by admitting evidence of the cocaine. To find plain error an appellate court must find that a "fundamental" error occurred at trial. Fundamental means that the error likely impacted the jury finding the Defendant guilty and seriously affected the "fairness, integrity, or public reputation of judicial proceedings." The Supreme Court overturned the appellate court's findings. The Supreme Court held that the "[D]efendant’s Fourth Amendment claims were not reviewable on direct appeal, even for plain error, because he completely waived them by not moving to suppress evidence of the cocaine before or at trial."
Link to Opinion
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State v. Miller, 893 S.E.2d 306 (S.C. 2023)
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South Carolina | 2023 | Criminal Justice, Juvenile Justice |
State:
South Carolina
Year:
2023
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingRobert Miller and two others forced their way into the victim’s home and murdered the victim. At the time, Miller was 15 years old. He later confessed four times, twice to friends and twice to law enforcement, with all four confessions admitted at trial. The trial court sentenced Miller to 55 years in prison, which the court of appeals affirmed. Miller appealed the admission of the fourth confession, which was made to two agents of the South Carolina Law Enforcement Division (SLED), arguing his statements were not made voluntarily and that his rights had been violated under both the Due Process Clause of the Fourteenth Amendment and his Fifth Amendment right against self-incrimination. First, the Supreme Court refined its standard of review, holding that it would review the trial court’s factual findings regarding voluntariness for evidentiary support, but that the ultimate legal conclusion (whether, based on the facts, a statement was voluntarily made) would be a question of law subject to de novo review. Next, the Supreme Court turned to Miller’s constitutional arguments. With respect to the due process challenge, the Supreme Court found that Miller’s confession was voluntary based on a totality of the circumstances, pointing to the fact that Miller had been advised of his constitutional rights, he had not been handcuffed, the SLED agents did not make him any explicit promises of leniency if he confessed, he had been comfortable when his stand-in parent left the room, and although his education level was limited, he was “pretty street smart” and had enough prior experiences with law enforcement to understand what was going on when he waived his rights and decided to talk to the SLED agents. With respect to the Fifth Amendment challenge, the Supreme Court held that Miller understood his rights before waiving them. The Supreme Court highlighted the fact that a police officer had properly advised Miller of his Miranda rights before questioning, that Miller had signed a waiver to that effect, and that despite his youth, Miller had already had multiple encounters with law enforcement in which he was mirandized and had those rights explained to him. Consequently, the Supreme Court held that Miller’s confession was voluntary under both the Fourteenth and Fifth Amendments.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Robert Miller and two others forced their way into the victim’s home and murdered the victim. At the time, Miller was 15 years old. He later confessed four times, twice to friends and twice to law enforcement, with all four confessions admitted at trial. The trial court sentenced Miller to 55 years in prison, which the court of appeals affirmed. Miller appealed the admission of the fourth confession, which was made to two agents of the South Carolina Law Enforcement Division (SLED), arguing his statements were not made voluntarily and that his rights had been violated under both the Due Process Clause of the Fourteenth Amendment and his Fifth Amendment right against self-incrimination. First, the Supreme Court refined its standard of review, holding that it would review the trial court’s factual findings regarding voluntariness for evidentiary support, but that the ultimate legal conclusion (whether, based on the facts, a statement was voluntarily made) would be a question of law subject to de novo review. Next, the Supreme Court turned to Miller’s constitutional arguments. With respect to the due process challenge, the Supreme Court found that Miller’s confession was voluntary based on a totality of the circumstances, pointing to the fact that Miller had been advised of his constitutional rights, he had not been handcuffed, the SLED agents did not make him any explicit promises of leniency if he confessed, he had been comfortable when his stand-in parent left the room, and although his education level was limited, he was “pretty street smart” and had enough prior experiences with law enforcement to understand what was going on when he waived his rights and decided to talk to the SLED agents. With respect to the Fifth Amendment challenge, the Supreme Court held that Miller understood his rights before waiving them. The Supreme Court highlighted the fact that a police officer had properly advised Miller of his Miranda rights before questioning, that Miller had signed a waiver to that effect, and that despite his youth, Miller had already had multiple encounters with law enforcement in which he was mirandized and had those rights explained to him. Consequently, the Supreme Court held that Miller’s confession was voluntary under both the Fourteenth and Fifth Amendments.
Link to Opinion
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State v. Minn. Sch. of Bus., Inc., 899 N.W.2d 467 (Minn. 2017)
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Minnesota | 2017 | Education, Access to Education/Funding |
State:
Minnesota
Year:
2017
Topics:
Education, Access to Education/Funding
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe State of Minnesota, through the Attorney General, filed an action in District Court to stop the Minnesota School of Business and Globe University (collectively the Schools) from charging usurious interest rates on loans and making private student loans without a license. Minnesota's general usury statute caps interest rates at eight percent for written contracts, however, lenders may charge up to 18 percent interest for a "consumer credit sale pursuant to an open end credit plan." The Supreme Court concluded that the schools, which offered student loans between $3K and $7.5K at interests between 12 and 18 percent, were not offering "open-end credit plans" and, thus, were not permitted to charge interest over eight percent. In addition, the Supreme Court concluded that because the loans were not made under an "open-end credit plan" the schools were also required to obtain a license, under the state's regulated loan law, to make such loans.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The State of Minnesota, through the Attorney General, filed an action in District Court to stop the Minnesota School of Business and Globe University (collectively the Schools) from charging usurious interest rates on loans and making private student loans without a license. Minnesota's general usury statute caps interest rates at eight percent for written contracts, however, lenders may charge up to 18 percent interest for a "consumer credit sale pursuant to an open end credit plan." The Supreme Court concluded that the schools, which offered student loans between $3K and $7.5K at interests between 12 and 18 percent, were not offering "open-end credit plans" and, thus, were not permitted to charge interest over eight percent. In addition, the Supreme Court concluded that because the loans were not made under an "open-end credit plan" the schools were also required to obtain a license, under the state's regulated loan law, to make such loans.
Link to Opinion
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State v. Mitcham, 559 P.3d 1099 (Ariz. 2024)
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Arizona | 2024 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2024
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant consented to a blood test to determine alcohol or drug content after being arrested for a DUI. Police drew two vials of blood—one for the test and one for Defendant to use for an independent test. Defendant signed a “Destruction Notice” that said police would destroy the second vial if Defendant did not ask for it within 90 days. Defendant never asked for the vial, but police failed to destroy it. Three years later, Defendant was suspected of a murder and, without obtaining a warrant, police compared Defendant’s DNA from the blood sample collected for the DUI to link him to the murder. Police then obtained warrants to search Defendant’s home, place a GPS tracker on his car, and obtain more DNA samples. The affidavits for the warrants described the use of the blood sample to link Defendant to the murder. Defendant moved to suppress the DNA evidence from his blood sample and the second collection of DNA reasoning the second collection was based on the first, which was obtained without a warrant. The trial court granted the motion, suppressing both. Following reversal by the appeals court, the Supreme Court reviewed and held that police’s warrantless search of Defendant’s blood violated Defendant’s Fourth Amendment rights and that the trial court erred in suppressing the evidence because the inevitable discovery exception to the exclusionary rule applied. The Court explained that sequencing DNA from Defendant’s blood was a search under the Fourth Amendment because the chemical analysis is an invasion of privacy separate from the blood draw. The Court determined the search was unreasonable because his consent to the blood draw and test was limited to the determining alcohol or drug content for the DUI and the second vial was supposed to be destroyed, therefore, a reasonable person would not have expected police to create a DNA profile. Next, the Court analyzed the applicability of an exception to the exclusionary rule to determine whether the trial court properly suppressed the evidence. The Court found that the inevitable discovery exception applied and, therefore, the trial court erred in suppressing the evidence. The inevitable discovery exception applies where the prosecution can show, by a preponderance of the evidence, that the information would have inevitably been discovered by lawful means. Here, the police would have eventually obtained Defendant’s DNA profile because he was recently sentenced to a term of imprisonment for other crimes in the Arizona Department of Corrections, Rehabilitation and Reentry, which is required by Arizona law to take a blood sample or other substance for purposes of DNA profiling which can then be used for law enforcement identification purposes in any criminal prosecution. Therefore, the Court reversed the trial court’s suppression decision.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant consented to a blood test to determine alcohol or drug content after being arrested for a DUI. Police drew two vials of blood—one for the test and one for Defendant to use for an independent test. Defendant signed a “Destruction Notice” that said police would destroy the second vial if Defendant did not ask for it within 90 days. Defendant never asked for the vial, but police failed to destroy it. Three years later, Defendant was suspected of a murder and, without obtaining a warrant, police compared Defendant’s DNA from the blood sample collected for the DUI to link him to the murder. Police then obtained warrants to search Defendant’s home, place a GPS tracker on his car, and obtain more DNA samples. The affidavits for the warrants described the use of the blood sample to link Defendant to the murder. Defendant moved to suppress the DNA evidence from his blood sample and the second collection of DNA reasoning the second collection was based on the first, which was obtained without a warrant. The trial court granted the motion, suppressing both. Following reversal by the appeals court, the Supreme Court reviewed and held that police’s warrantless search of Defendant’s blood violated Defendant’s Fourth Amendment rights and that the trial court erred in suppressing the evidence because the inevitable discovery exception to the exclusionary rule applied. The Court explained that sequencing DNA from Defendant’s blood was a search under the Fourth Amendment because the chemical analysis is an invasion of privacy separate from the blood draw. The Court determined the search was unreasonable because his consent to the blood draw and test was limited to the determining alcohol or drug content for the DUI and the second vial was supposed to be destroyed, therefore, a reasonable person would not have expected police to create a DNA profile. Next, the Court analyzed the applicability of an exception to the exclusionary rule to determine whether the trial court properly suppressed the evidence. The Court found that the inevitable discovery exception applied and, therefore, the trial court erred in suppressing the evidence. The inevitable discovery exception applies where the prosecution can show, by a preponderance of the evidence, that the information would have inevitably been discovered by lawful means. Here, the police would have eventually obtained Defendant’s DNA profile because he was recently sentenced to a term of imprisonment for other crimes in the Arizona Department of Corrections, Rehabilitation and Reentry, which is required by Arizona law to take a blood sample or other substance for purposes of DNA profiling which can then be used for law enforcement identification purposes in any criminal prosecution. Therefore, the Court reversed the trial court’s suppression decision.
Link to Opinion
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State v. Mixton, 478 P.3d 1227 (Ariz. 2021)
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Arizona | 2021 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2021
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAn undercover Tucson police department detective posted an advertisement on an online forum seeking users interested in child pornography. Defendant responded, which led the police to request a federal administrative subpoena to the custodian of the Defendant's IP address for the personal information associated with the Defendant's IP address. The custodian complied, and with this information, the police executed a search warrant on the Defendant's home. The Supreme Court reviewed the issue of whether the police need a search warrant to obtain an IP address under the Fourth Amendment. The Court held that “the Fourth Amendment does not protect IP addresses and ISP subscriber information because such information falls within the exception created by the ‘third-party doctrine.’” Importantly, the information such as an IP address is not private because it is shared with others. A person has no expectation of privacy in information he voluntarily discloses to third parties, even if there is an assumption it will be used only for a limited purpose. The Court stated that “[a]s with bank records and dialed telephone numbers, an internet user voluntarily provides subscriber information and IP addresses to third-party ISPs and servers. Subscriber information and IP addresses also do not reveal the substance or content of the internet user’s communication any more than the information affixed to the exterior of a mailed item.” Additionally, in reviewing Article 2, Section 8 of Arizona's constitution, the Court held that the "Private Affairs Clause" also does not require the state to obtain a warrant to get a person's IP address or ISP information. The majority rejected the dissent's reference to Boyd v. United States, 116 U.S. 616 (1886) as a avenue for business records to be protected by the Private Affairs Clause because "it merely held that the Fourth and Fifth Amendments foreclose the government from compelling a defendant business owner in a criminal and forfeiture case, without a warrant, to produce at trial self-incriminating business records."
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Justice Vote Breakdown
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Summary of Case Context & Holding
An undercover Tucson police department detective posted an advertisement on an online forum seeking users interested in child pornography. Defendant responded, which led the police to request a federal administrative subpoena to the custodian of the Defendant's IP address for the personal information associated with the Defendant's IP address. The custodian complied, and with this information, the police executed a search warrant on the Defendant's home. The Supreme Court reviewed the issue of whether the police need a search warrant to obtain an IP address under the Fourth Amendment. The Court held that “the Fourth Amendment does not protect IP addresses and ISP subscriber information because such information falls within the exception created by the ‘third-party doctrine.’” Importantly, the information such as an IP address is not private because it is shared with others. A person has no expectation of privacy in information he voluntarily discloses to third parties, even if there is an assumption it will be used only for a limited purpose. The Court stated that “[a]s with bank records and dialed telephone numbers, an internet user voluntarily provides subscriber information and IP addresses to third-party ISPs and servers. Subscriber information and IP addresses also do not reveal the substance or content of the internet user’s communication any more than the information affixed to the exterior of a mailed item.” Additionally, in reviewing Article 2, Section 8 of Arizona's constitution, the Court held that the "Private Affairs Clause" also does not require the state to obtain a warrant to get a person's IP address or ISP information. The majority rejected the dissent's reference to Boyd v. United States, 116 U.S. 616 (1886) as a avenue for business records to be protected by the Private Affairs Clause because "it merely held that the Fourth and Fifth Amendments foreclose the government from compelling a defendant business owner in a criminal and forfeiture case, without a warrant, to produce at trial self-incriminating business records."
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State v. Mont. Thirteenth Jud. Dist. Ct., No. OP 22-0552, 2023 WL 142673 (Mont. Jan. 10, 2023)
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Montana | 2023 | LGBTQ+ Rights, Anti-Transgender Legislation, LGBTQ+ Discrimination |
State:
Montana
Year:
2023
Topics:
LGBTQ+ Rights, Anti-Transgender Legislation, LGBTQ+ Discrimination
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingMontana enacted Senate Bill 280 (SB 280) on April 30, 2021, which provides, in relevant part, that the "sex of a person designated on a birth certificate may be amended only if the Montana Department of Health and Human Services (DPHHS) receives a certified copy of an order from a court with appropriate jurisdiction indicating that the sex of the person born in Montana has been changed by surgical procedure." SB 280 repealed a prior 2017 Rule, which created a simpler process by which Montanans could change the sex designation on their birth certificate without needing a court order. Plaintiffs, transgender individuals, filed a lawsuit challenging enactment of SB 280 on the ground that it violated their constitutional right to privacy, equal protection, and due process. In April 2022, the Yellowstone County District Court granted a preliminary injunction that enjoined the state from enforcing any aspect of SB 280 during the pendency of plaintiffs' action, and restoring the 2017 Rule. The state appealed to the Supreme Court arguing that DPHHS does not need to follow the district court's order that it reinstate the 2017 Rule. The Supreme Court’s confirmed that the preliminary injunction granted by the Yellowstone County District Court on April 21, 2022 restored the 2017 Rule that was in place prior to the state’s passage of SB 280.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Montana enacted Senate Bill 280 (SB 280) on April 30, 2021, which provides, in relevant part, that the "sex of a person designated on a birth certificate may be amended only if the Montana Department of Health and Human Services (DPHHS) receives a certified copy of an order from a court with appropriate jurisdiction indicating that the sex of the person born in Montana has been changed by surgical procedure." SB 280 repealed a prior 2017 Rule, which created a simpler process by which Montanans could change the sex designation on their birth certificate without needing a court order. Plaintiffs, transgender individuals, filed a lawsuit challenging enactment of SB 280 on the ground that it violated their constitutional right to privacy, equal protection, and due process. In April 2022, the Yellowstone County District Court granted a preliminary injunction that enjoined the state from enforcing any aspect of SB 280 during the pendency of plaintiffs' action, and restoring the 2017 Rule. The state appealed to the Supreme Court arguing that DPHHS does not need to follow the district court's order that it reinstate the 2017 Rule. The Supreme Court’s confirmed that the preliminary injunction granted by the Yellowstone County District Court on April 21, 2022 restored the 2017 Rule that was in place prior to the state’s passage of SB 280.
Link to Opinion
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State v. Montalvo, 162 A.3d 270 (N.J. 2017)
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New Jersey | 2017 | Criminal Justice |
State:
New Jersey
Year:
2017
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe case before the Supreme Court involved a dispute between two neighbors, resulting in the upstairs neighbor knocking on Defendant's door. Defendant reported that the neighbor was kicking and slamming the door and that Defendant was scared for himself, his wife, and their unborn child. Defendant thought the neighbor may have a gun and the Defendant retrieved a machete that he had used in his roofing job from a closet before he answered the door. The neighbor testified that the Defendant was holding the machete at an angle as if it was "ready to chop" whereas the Defendant testified that the machete was held down behind his leg. Defendant never stepped outside with the machete. The neighbor called the police and upon their arrival, the Defendant told the police that he grabbed the machete because he feared for his and his wife's lives. Defendant was charged with possession of a weapon for an unlawful purpose and knowing possession of a machete under circumstances not manifestly appropriate for such lawful uses as it may have. The Defendant was convicted on both counts and on appeal asserted that the trial judge's jury instructions were plainly erroneous because the jury charge was not tailored to his claim of self defense. The Supreme Court explained that the Second Amendment protects a defendant's right to possess weapons, including machetes, in the home for self-defense purposes. The Court further held that the jury instructions were capable of producing an unjust result because the instructions permitted the jurors to convict the Defendant on an invalid theory of guilt--holding the machete when answering the door, without a self-defense instruction. The Court directed the Committee on Model Criminal Jury Charges to revise the charge in question to make clear that possession of a lawful weapon in one's home cannot form the basis of a conviction under N.J.S.A. 2C:39-5(d) (possession of a weapon under circumstances not manifestly appropriate for such lawful uses) and that individuals may possess objects in their home for multiple lawful purposes, including anticipatory self-defense.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The case before the Supreme Court involved a dispute between two neighbors, resulting in the upstairs neighbor knocking on Defendant's door. Defendant reported that the neighbor was kicking and slamming the door and that Defendant was scared for himself, his wife, and their unborn child. Defendant thought the neighbor may have a gun and the Defendant retrieved a machete that he had used in his roofing job from a closet before he answered the door. The neighbor testified that the Defendant was holding the machete at an angle as if it was "ready to chop" whereas the Defendant testified that the machete was held down behind his leg. Defendant never stepped outside with the machete. The neighbor called the police and upon their arrival, the Defendant told the police that he grabbed the machete because he feared for his and his wife's lives. Defendant was charged with possession of a weapon for an unlawful purpose and knowing possession of a machete under circumstances not manifestly appropriate for such lawful uses as it may have. The Defendant was convicted on both counts and on appeal asserted that the trial judge's jury instructions were plainly erroneous because the jury charge was not tailored to his claim of self defense. The Supreme Court explained that the Second Amendment protects a defendant's right to possess weapons, including machetes, in the home for self-defense purposes. The Court further held that the jury instructions were capable of producing an unjust result because the instructions permitted the jurors to convict the Defendant on an invalid theory of guilt--holding the machete when answering the door, without a self-defense instruction. The Court directed the Committee on Model Criminal Jury Charges to revise the charge in question to make clear that possession of a lawful weapon in one's home cannot form the basis of a conviction under N.J.S.A. 2C:39-5(d) (possession of a weapon under circumstances not manifestly appropriate for such lawful uses) and that individuals may possess objects in their home for multiple lawful purposes, including anticipatory self-defense.
Link to Opinion
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State v. Moore, 76 N.E.3d 1127 (Ohio 2016)
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Ohio | 2016 | Criminal Justice, Juvenile Justice |
State:
Ohio
Year:
2016
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAfter robbing at gunpoint other victims, the Defendant kidnapped a woman in the parking lot of her job and violently assaulted and raped her with another person multiple times at gun point. The Defendant was resentenced on remand to an aggregate 112-year prison sentence for a non-homicide offense committed by the Defendant when he was 15 years old. On appeal, the Defendant argued that the Eighth Amendment prohibits sentencing a juvenile to a term-of-years sentence that precludes any possibility of release during the juvenile's life expectancy. The Supreme Court extended prior precedent that non-homicide juvenile offenders could not be sentenced to life imprisonment to also specify that non-homicide juvenile offenders may not be sentenced to a term-of-years that exceeds their life expectancy. Additionally, the Supreme Court clarified that "nonhomicide juvenile offenders" includes juveniles who commit multiple offenses, as long as none were homicides.
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Justice Vote Breakdown
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Summary of Case Context & Holding
After robbing at gunpoint other victims, the Defendant kidnapped a woman in the parking lot of her job and violently assaulted and raped her with another person multiple times at gun point. The Defendant was resentenced on remand to an aggregate 112-year prison sentence for a non-homicide offense committed by the Defendant when he was 15 years old. On appeal, the Defendant argued that the Eighth Amendment prohibits sentencing a juvenile to a term-of-years sentence that precludes any possibility of release during the juvenile's life expectancy. The Supreme Court extended prior precedent that non-homicide juvenile offenders could not be sentenced to life imprisonment to also specify that non-homicide juvenile offenders may not be sentenced to a term-of-years that exceeds their life expectancy. Additionally, the Supreme Court clarified that "nonhomicide juvenile offenders" includes juveniles who commit multiple offenses, as long as none were homicides.
Link to Opinion
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State v. Moore, 864 N.W.2d 376 (Wis. 2015)
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Wisconsin | 2015 | Criminal Justice, Juvenile Justice, Police Misconduct and Bias |
State:
Wisconsin
Year:
2015
Topics:
Criminal Justice, Juvenile Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingJuvenile Defendant was charged with second-degree reckless homicide. He moved to suppress his confession, which was taken in a custodial interrogation. During the interrogation the Defendant asked the police to turn off an audio recorder. Under Wisconsin law, police must record interrogations unless the defendant refuses to cooperate in the presence of the audio recorder. The Supreme Court ruled that the Defendant’s request was a refusal to cooperate and that his confession, which was later covertly recorded, was admissible. Specifically, the Supreme Court held that: (1) Defendant's confession was voluntary because the pressures placed on Defendant by the interrogation did not “excee[d his] ability to resist” and the detectives ensured that Defendant understood his Miranda rights and treated him with decency and respect; and (2) Defendant did not refuse to respond or cooperate, as required to invoke exception to requirement that interrogation be recorded because Defendant continued making statements and answering questions and never told the detectives he would end the interrogation or stop answering questions if the recorder was left on. The Supreme Court determined that the failure to record parts of Defendant's interrogation violated Wis. Stat. § 938.195, but held that any error in admitting Defendant's confession was harmless in this case. The Supreme Court stated that the harmless error inquiry asks “whether it was ‘beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’" Here, the state still had ample evidence to support the charge that Defendant ultimately pled to, so the Supreme Court was persuaded beyond a reasonable doubt that Defendant would have pled guilty to the same charge regardless of any possible error made by the circuit court in denying suppression of Defendant's unrecorded statements.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Juvenile Defendant was charged with second-degree reckless homicide. He moved to suppress his confession, which was taken in a custodial interrogation. During the interrogation the Defendant asked the police to turn off an audio recorder. Under Wisconsin law, police must record interrogations unless the defendant refuses to cooperate in the presence of the audio recorder. The Supreme Court ruled that the Defendant’s request was a refusal to cooperate and that his confession, which was later covertly recorded, was admissible. Specifically, the Supreme Court held that: (1) Defendant's confession was voluntary because the pressures placed on Defendant by the interrogation did not “excee[d his] ability to resist” and the detectives ensured that Defendant understood his Miranda rights and treated him with decency and respect; and (2) Defendant did not refuse to respond or cooperate, as required to invoke exception to requirement that interrogation be recorded because Defendant continued making statements and answering questions and never told the detectives he would end the interrogation or stop answering questions if the recorder was left on. The Supreme Court determined that the failure to record parts of Defendant's interrogation violated Wis. Stat. § 938.195, but held that any error in admitting Defendant's confession was harmless in this case. The Supreme Court stated that the harmless error inquiry asks “whether it was ‘beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’" Here, the state still had ample evidence to support the charge that Defendant ultimately pled to, so the Supreme Court was persuaded beyond a reasonable doubt that Defendant would have pled guilty to the same charge regardless of any possible error made by the circuit court in denying suppression of Defendant's unrecorded statements.
Link to Opinion
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State v. Morris, 222 N.E.3d 568 (Ohio 2022)
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Ohio | 2022 | Criminal Justice, Juvenile Justice |
State:
Ohio
Year:
2022
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingJuvenile Defendant was an accomplice to murder in connection to the sell of meth and was charged with an offense that was bound over from juvenile court to general court to be tried as an adult. The jury found him guilty and he was sentenced to an indefinite life sentence with parole eligibility after 38 to 43 years. The Defendant filed an appeal in which he argued, among several other assignments of error, that the trial court erred in its sentencing of him because it failed to consider his youth as a factor. The court of appeals overruled his assignments of error and affirmed his conviction and sentence and he subsequently appealed again. The Supreme Court concluded that, despite the U.S. Supreme Court’s decision in Jones v. Mississippi, 141 S. Ct. 1307 (2021)–which required sentencing courts to make a separate factual finding of permanent incorrigibility before imposing on a juvenile a life sentence without parole, Ohio continues to have a requirement that a court must expressly consider the juvenile’s youth as a mitigating factor in exercising its discretion as to what life sentence to impose on a juvenile convicted for aggravated murder or complicity in aggravated murder.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Juvenile Defendant was an accomplice to murder in connection to the sell of meth and was charged with an offense that was bound over from juvenile court to general court to be tried as an adult. The jury found him guilty and he was sentenced to an indefinite life sentence with parole eligibility after 38 to 43 years. The Defendant filed an appeal in which he argued, among several other assignments of error, that the trial court erred in its sentencing of him because it failed to consider his youth as a factor. The court of appeals overruled his assignments of error and affirmed his conviction and sentence and he subsequently appealed again. The Supreme Court concluded that, despite the U.S. Supreme Court’s decision in Jones v. Mississippi, 141 S. Ct. 1307 (2021)–which required sentencing courts to make a separate factual finding of permanent incorrigibility before imposing on a juvenile a life sentence without parole, Ohio continues to have a requirement that a court must expressly consider the juvenile’s youth as a mitigating factor in exercising its discretion as to what life sentence to impose on a juvenile convicted for aggravated murder or complicity in aggravated murder.
Link to Opinion
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State v. Mouelle, 922 N.W.2d 706 (Minn. 2019)
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Minnesota | 2019 | Criminal Justice, Access to Justice |
State:
Minnesota
Year:
2019
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant was found guilty of first-degree premeditated murder and first-degree premeditated murder of an unborn child. On appeal, Appellant asserted (i) that the district court judge should not have presided over the trial after having heard a comment by defense counsel during an ex parte conversation suggesting Appellant might commit perjury; (ii) that his right to effective assistance of counsel was violated when defense counsel disclosed client communications during the ex parte communication with the judge; (iii) the district court clearly erred in its jury instructions; and (iv) his life imprisonment without possibility of parole sentence for the murder of an unborn child was not authorized by Minnesota statute. The Supreme Court explained: (i) Counsel's concerns regarding Appellant's truthfulness were never mentioned again, and the jury (the fact finder) was never exposed to those concerns; (ii) Appellant's counsel's concerns regarding Appellant's truthfulness were never called to the attention of the fact finder, and while the judge made evidentiary rulings throughout, adverse rulings do not demonstrate bias; (iii) the jury instruction did not state that the killing of the unborn child had to be premeditated, the finding of murder in the first degree encompassed and required premeditation, and the State produced overwhelming evidence that there was premeditation; and (iv) based on the plain language of the Minnesota statute on heinous crimes, murder of an unborn child does not authorize a sentence of life imprisonment without possibility of release for conviction of first degree murder of an unborn child. On these grounds, the Supreme Court affirmed Appellant's convictions, reversed the sentence for conviction of first degree premeditated murder of an unborn child, and remanded.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant was found guilty of first-degree premeditated murder and first-degree premeditated murder of an unborn child. On appeal, Appellant asserted (i) that the district court judge should not have presided over the trial after having heard a comment by defense counsel during an ex parte conversation suggesting Appellant might commit perjury; (ii) that his right to effective assistance of counsel was violated when defense counsel disclosed client communications during the ex parte communication with the judge; (iii) the district court clearly erred in its jury instructions; and (iv) his life imprisonment without possibility of parole sentence for the murder of an unborn child was not authorized by Minnesota statute. The Supreme Court explained: (i) Counsel's concerns regarding Appellant's truthfulness were never mentioned again, and the jury (the fact finder) was never exposed to those concerns; (ii) Appellant's counsel's concerns regarding Appellant's truthfulness were never called to the attention of the fact finder, and while the judge made evidentiary rulings throughout, adverse rulings do not demonstrate bias; (iii) the jury instruction did not state that the killing of the unborn child had to be premeditated, the finding of murder in the first degree encompassed and required premeditation, and the State produced overwhelming evidence that there was premeditation; and (iv) based on the plain language of the Minnesota statute on heinous crimes, murder of an unborn child does not authorize a sentence of life imprisonment without possibility of release for conviction of first degree murder of an unborn child. On these grounds, the Supreme Court affirmed Appellant's convictions, reversed the sentence for conviction of first degree premeditated murder of an unborn child, and remanded.
Link to Opinion
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State v. Muhammad, 513 P.3d 1095 (Ariz. 2022)
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Arizona | 2022 | Criminal Justice |
State:
Arizona
Year:
2022
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingRahim Muhammad, while incarcerated, was charged with thirteen counts of aggravated harassment for sending threatening letters to a Department of Corrections employee in violation of court orders. After undergoing multiple psychological evaluations, Muhammad was found competent to stand trial. He later waived his right to a jury trial, and the trial court accepted the waiver. On appeal, Muhammad argued that the court should have made a heightened competency finding before accepting his waiver. The Arizona Supreme Court rejected this argument, holding that Arizona law does not require a specific finding of heightened competency for a jury-trial waiver, even when competency has been at issue. The Court affirmed Muhammad’s convictions, concluding that the trial court did not abuse its discretion in determining that the waiver was knowing, voluntary, and intelligent.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Rahim Muhammad, while incarcerated, was charged with thirteen counts of aggravated harassment for sending threatening letters to a Department of Corrections employee in violation of court orders. After undergoing multiple psychological evaluations, Muhammad was found competent to stand trial. He later waived his right to a jury trial, and the trial court accepted the waiver. On appeal, Muhammad argued that the court should have made a heightened competency finding before accepting his waiver. The Arizona Supreme Court rejected this argument, holding that Arizona law does not require a specific finding of heightened competency for a jury-trial waiver, even when competency has been at issue. The Court affirmed Muhammad’s convictions, concluding that the trial court did not abuse its discretion in determining that the waiver was knowing, voluntary, and intelligent.
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State v. Munt, 831 N.W.2d 569 (Minn. 2013)
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Minnesota | 2013 | Criminal Justice, Access to Justice |
State:
Minnesota
Year:
2013
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAppellant was indicted of various offenses arising out of the shooting of his ex-wife and the kidnapping of their three children. Appellant pleaded not guilty and not guilty by reason of mental illness. During the trial, the judge made a comment that the following week the district court and jurors would need to return for the second phase of the trial to hear expert witness testimony from a psychologist. Subsequently the jury rejected the not-guilty-by-reason-of-mental-illness defense. Appellant directly appealed and argued that the district court erred when it declined to remove a prospective juror, who stated in voire dire that if you confess your guilt you should be held responsible, "mental illness or not," after having noted that they would be able to follow the legal instructions and render a fair and impartial verdict in the case. The Supreme Court held that Appellant failed to establish that the potential juror's statement expressed actual bias because: (i) the record did not support the assumption that the meaning of "mental illness" as stated by the juror was the same as the standard for mental illness or deficiency as codified in Minn. Stat. § 611.026 (mental illness or deficiency arising to a "defect of reason" so "as not to know the nature of the act, or that it was wrong") excusing criminal liability, because the prosecutor and district court did not explain that the mental illness defense has a specialized legal meaning; and (ii) the answer concerning "mental illness," in conjunction with the other answers given by the potential juror (such as the juror's statement that they would be able to follow all the instructions on the law, and that there was no reason they would be unable to render a fair and impartial verdict in the case), did not indicate an inability to set aside their personal opinion and fairly evaluate the case at hand. Appellant also argued that the judge's comment concerning a planned second phase of the trial, showed that the judge was convinced Appellant was guilty, and that he was therefore biased against the Appellant. The Supreme Court held that the judge's statement did not show that he was biased, but rather was only intended to assist the jurors in planning their personal schedules. As a result the Supreme Court affirmed the district court's decision.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant was indicted of various offenses arising out of the shooting of his ex-wife and the kidnapping of their three children. Appellant pleaded not guilty and not guilty by reason of mental illness. During the trial, the judge made a comment that the following week the district court and jurors would need to return for the second phase of the trial to hear expert witness testimony from a psychologist. Subsequently the jury rejected the not-guilty-by-reason-of-mental-illness defense. Appellant directly appealed and argued that the district court erred when it declined to remove a prospective juror, who stated in voire dire that if you confess your guilt you should be held responsible, "mental illness or not," after having noted that they would be able to follow the legal instructions and render a fair and impartial verdict in the case. The Supreme Court held that Appellant failed to establish that the potential juror's statement expressed actual bias because: (i) the record did not support the assumption that the meaning of "mental illness" as stated by the juror was the same as the standard for mental illness or deficiency as codified in Minn. Stat. § 611.026 (mental illness or deficiency arising to a "defect of reason" so "as not to know the nature of the act, or that it was wrong") excusing criminal liability, because the prosecutor and district court did not explain that the mental illness defense has a specialized legal meaning; and (ii) the answer concerning "mental illness," in conjunction with the other answers given by the potential juror (such as the juror's statement that they would be able to follow all the instructions on the law, and that there was no reason they would be unable to render a fair and impartial verdict in the case), did not indicate an inability to set aside their personal opinion and fairly evaluate the case at hand. Appellant also argued that the judge's comment concerning a planned second phase of the trial, showed that the judge was convinced Appellant was guilty, and that he was therefore biased against the Appellant. The Supreme Court held that the judge's statement did not show that he was biased, but rather was only intended to assist the jurors in planning their personal schedules. As a result the Supreme Court affirmed the district court's decision.
Link to Opinion
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State v. Murchison, 758 S.E.2d 356 (N.C. 2014)
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North Carolina | 2014 | Criminal Justice, Police Misconduct and Bias |
State:
North Carolina
Year:
2014
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingProbation officer filed violation reports alleging probationer had been charged with criminal offenses in violation of condition of probationer's probation for convictions for assault with a deadly weapon with intent to kill, assault with a deadly weapon, and possession with intent to sell or deliver marijuana. The superior court revoked probation and activated probationer's suspended sentences. Probationer appealed. The court of appeals reversed on the basis that the trial court abused its discretion by basing the revocation on hearsay evidence alone, in particular, with respect to evidence provided by the Defendant's probation officer that Defendant had violated numerous conditions of his probation such as committing assault with a deadly weapon, missing curfews and failing to attend counselling. The State petitioned for discretionary review, which was granted. The Supreme Court reversed the court of appeals, finding that because the proceeding was a probation revocation hearing, the trial court was not bound by the formal rules of evidence and acted within its discretion when it admitted the hearsay evidence of the probation officer.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Probation officer filed violation reports alleging probationer had been charged with criminal offenses in violation of condition of probationer's probation for convictions for assault with a deadly weapon with intent to kill, assault with a deadly weapon, and possession with intent to sell or deliver marijuana. The superior court revoked probation and activated probationer's suspended sentences. Probationer appealed. The court of appeals reversed on the basis that the trial court abused its discretion by basing the revocation on hearsay evidence alone, in particular, with respect to evidence provided by the Defendant's probation officer that Defendant had violated numerous conditions of his probation such as committing assault with a deadly weapon, missing curfews and failing to attend counselling. The State petitioned for discretionary review, which was granted. The Supreme Court reversed the court of appeals, finding that because the proceeding was a probation revocation hearing, the trial court was not bound by the formal rules of evidence and acted within its discretion when it admitted the hearsay evidence of the probation officer.
Link to Opinion
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State v. Murphy, 371 P.3d 991 (Nev. 2016)
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Nevada | 2016 | Labor, Employment & Economic Justice |
State:
Nevada
Year:
2016
Topics:
Labor, Employment & Economic Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAn employee's employment was terminated because he failed to show up at work due to his incarceration, and based on a plain reading of Nev. Rev. Stat. § 612.385, an employee who is terminated as a result of missing work due to incarceration after being convicted of a crime is not eligible for unemployment benefits. Although the employee stated that he could not afford bail, his absence from work was directly caused by his criminal conduct. The employee pleaded guilty to the charges against him, and, therefore, was disqualified from receiving benefits under Nevada statute § 612,385. The Supreme Court held that that an employee who is terminated as a result of missing work due to incarceration, and who is subsequently convicted of a crime, is not eligible for unemployment benefits.
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Justice Vote Breakdown
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Summary of Case Context & Holding
An employee's employment was terminated because he failed to show up at work due to his incarceration, and based on a plain reading of Nev. Rev. Stat. § 612.385, an employee who is terminated as a result of missing work due to incarceration after being convicted of a crime is not eligible for unemployment benefits. Although the employee stated that he could not afford bail, his absence from work was directly caused by his criminal conduct. The employee pleaded guilty to the charges against him, and, therefore, was disqualified from receiving benefits under Nevada statute § 612,385. The Supreme Court held that that an employee who is terminated as a result of missing work due to incarceration, and who is subsequently convicted of a crime, is not eligible for unemployment benefits.
Link to Opinion
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State v. Murray, 482 P.3d 1038 (Ariz. 2021)
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Arizona | 2021 | Criminal Justice, Access to Justice |
State:
Arizona
Year:
2021
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendants were convicted of aggravated assault and separately appealed, alleging (among other things) that statements made by the prosecutor at trial regarding the reasonable-doubt standard constituted fundamental, prejudicial error. Specifically, the prosecutor invited jurors to conclude, if they thought one or both Defendants might be guilty, that they must have been persuaded by the evidence beyond a reasonable doubt, which radically departs from the requisite "firmly convinced" standard. The court of appeals affirmed the convictions in separate panel decisions, and Defendants separately appealed. The Supreme Court vacated the decisions of the court of appeals, holding that the prosecutor's misstatement of the reasonable-doubt standard during a rebuttal argument constituted fundamental error and was prejudicial. Specifically, the Supreme Court held (1) the prosecutor’s material misstatement of the reasonable-doubt standard was both fundamental error and prejudicial error because it went to the foundation of the case and deprived Defendants of an "essential right" necessary to rebut the State's case; and (2) neither the jury instructions nor the presumption that the jury followed the court's instructions cured the prejudice.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendants were convicted of aggravated assault and separately appealed, alleging (among other things) that statements made by the prosecutor at trial regarding the reasonable-doubt standard constituted fundamental, prejudicial error. Specifically, the prosecutor invited jurors to conclude, if they thought one or both Defendants might be guilty, that they must have been persuaded by the evidence beyond a reasonable doubt, which radically departs from the requisite "firmly convinced" standard. The court of appeals affirmed the convictions in separate panel decisions, and Defendants separately appealed. The Supreme Court vacated the decisions of the court of appeals, holding that the prosecutor's misstatement of the reasonable-doubt standard during a rebuttal argument constituted fundamental error and was prejudicial. Specifically, the Supreme Court held (1) the prosecutor’s material misstatement of the reasonable-doubt standard was both fundamental error and prejudicial error because it went to the foundation of the case and deprived Defendants of an "essential right" necessary to rebut the State's case; and (2) neither the jury instructions nor the presumption that the jury followed the court's instructions cured the prejudice.
Link to Opinion
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State v. Nash, 58 A.3d 705 (N.J. 2013)
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New Jersey | 2013 | Criminal Justice, Access to Justice |
State:
New Jersey
Year:
2013
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe issue presented to the New Jersey Supreme Court was whether a middle-school librarian convicted of aggravated sexual assault and endangering the welfare of a child is entitled to a new trial because exculpatory evidence—unknown to both the prosecutor and defense attorney—was not disclosed to the jury. At a trial in 2002, a special-education student (JB) testified that the Defendant (Askia Nash) sexually assaulted him on three unspecified dates between 1999 and October 2000, when the student was about twelve years old. Nash both denied the charge and insisted he could not have committed the crime because an aide escorted JB around campus at all times. The State called the school principal, who testified that JB was not assigned a personal aide, which undermined Nash's defense. Nash was convicted of sexually assaulting JB and endangering the welfare of another student who stated that Nash had inappropriately touched his shoulders and buttocks. In 2002 and 2005, Nash presented to the trial court newly discovered evidence, including by the principal himself, that JB was assigned a classroom aide who accompanied him throughout the day. None of the lower courts determined on the merits whether Nash was entitled to a new trial based on newly discovered evidence. The New Jersey Supreme Court held that the evidence that JB was assigned an aide who accompanied him throughout most of the day (which was not disclosed to the jury) is newly discovered evidence that, if presented to the jury, would probably have changed the outcome of the case. As a result, the Supreme Court determined that the integrity of the verdict had been cast in doubt, and a new trial must be ordered on all charges.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The issue presented to the New Jersey Supreme Court was whether a middle-school librarian convicted of aggravated sexual assault and endangering the welfare of a child is entitled to a new trial because exculpatory evidence—unknown to both the prosecutor and defense attorney—was not disclosed to the jury. At a trial in 2002, a special-education student (JB) testified that the Defendant (Askia Nash) sexually assaulted him on three unspecified dates between 1999 and October 2000, when the student was about twelve years old. Nash both denied the charge and insisted he could not have committed the crime because an aide escorted JB around campus at all times. The State called the school principal, who testified that JB was not assigned a personal aide, which undermined Nash's defense. Nash was convicted of sexually assaulting JB and endangering the welfare of another student who stated that Nash had inappropriately touched his shoulders and buttocks. In 2002 and 2005, Nash presented to the trial court newly discovered evidence, including by the principal himself, that JB was assigned a classroom aide who accompanied him throughout the day. None of the lower courts determined on the merits whether Nash was entitled to a new trial based on newly discovered evidence. The New Jersey Supreme Court held that the evidence that JB was assigned an aide who accompanied him throughout most of the day (which was not disclosed to the jury) is newly discovered evidence that, if presented to the jury, would probably have changed the outcome of the case. As a result, the Supreme Court determined that the integrity of the verdict had been cast in doubt, and a new trial must be ordered on all charges.
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State v. Naylor, 466 S.W.3d 783 (Tex. 2015)
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Texas | 2015 | LGBTQ+ Rights, LGBTQ+ Discrimination |
State:
Texas
Year:
2015
Topics:
LGBTQ+ Rights, LGBTQ+ Discrimination
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingTexas resident Angelique Naylor, who married Sabina Daly in Massachusetts in 2004, filed for divorce in Travis County, Texas, hoping to obtain a judgment addressing the couple's rights with respect to raising a child and operating a business together. Daly contested the divorce, citing that the Texas Constitution unambiguously provided that marriage "shall consist only of the union of one man and one woman" and the Texas Family Code, Section 6.204 did not allow Texas courts to "give effect" to such arrangements, such as implicitly recognizing the marriage by issuing a divorce decree. Daly argued the court could only declare the marriage void. The district court acknowledged Daly's concerns but granted an ostensible divorce after a two-day hearing, with the record stipulating that the judgment was intended to be a substitute for a valid divorce "dispos[ing] of all economic issues and liabilities as between the parties whether they [are] divorced or not." Lawyers from the Texas Attorney General's Office were present during the hearing and the announcement of the trial court's decision. However, the State did not file a petition to intervene until the day after the decision, to defend the constitutionality of Texas and federal laws that limit divorce actions to persons of the opposite sex. Both Naylor and Daly objected to the State's untimely attempted intervention. After a hearing on the contested intervention, the trial court decided not to grant the State's petition given its lack of timeliness but indicated the State could seek appellate review. The court of appeals dismissed the State's appeal, holding that the intervention was untimely and finding no basis for appellate standing. The Supreme Court agreed with the court of appeals, holding that the State lacked standing to appeal the trial court's decree. The Supreme Court determined that appellate standing is afforded to "parties of record," and accordingly appeals filed by improper parties must be dismissed. Justice Willett wrote a dissent, joined by Justices Guzman and Devine, contending that the State should have been allowed to intervene. Justice Willett, focusing on the subject-matter jurisdiction issue in the case, determined that even if the attorney general waited too long to raise the argument that Texas courts have no power to dissolve a same-sex marriage, if his argument was right, then the divorce would be void and challengeable. In his separate dissent, Justice Devine resolved the open question left in Justice Willett's dissent explaining that Texas law divests state courts of subject matter jurisdiction over same-sex proceedings.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Texas resident Angelique Naylor, who married Sabina Daly in Massachusetts in 2004, filed for divorce in Travis County, Texas, hoping to obtain a judgment addressing the couple's rights with respect to raising a child and operating a business together. Daly contested the divorce, citing that the Texas Constitution unambiguously provided that marriage "shall consist only of the union of one man and one woman" and the Texas Family Code, Section 6.204 did not allow Texas courts to "give effect" to such arrangements, such as implicitly recognizing the marriage by issuing a divorce decree. Daly argued the court could only declare the marriage void. The district court acknowledged Daly's concerns but granted an ostensible divorce after a two-day hearing, with the record stipulating that the judgment was intended to be a substitute for a valid divorce "dispos[ing] of all economic issues and liabilities as between the parties whether they [are] divorced or not." Lawyers from the Texas Attorney General's Office were present during the hearing and the announcement of the trial court's decision. However, the State did not file a petition to intervene until the day after the decision, to defend the constitutionality of Texas and federal laws that limit divorce actions to persons of the opposite sex. Both Naylor and Daly objected to the State's untimely attempted intervention. After a hearing on the contested intervention, the trial court decided not to grant the State's petition given its lack of timeliness but indicated the State could seek appellate review. The court of appeals dismissed the State's appeal, holding that the intervention was untimely and finding no basis for appellate standing. The Supreme Court agreed with the court of appeals, holding that the State lacked standing to appeal the trial court's decree. The Supreme Court determined that appellate standing is afforded to "parties of record," and accordingly appeals filed by improper parties must be dismissed. Justice Willett wrote a dissent, joined by Justices Guzman and Devine, contending that the State should have been allowed to intervene. Justice Willett, focusing on the subject-matter jurisdiction issue in the case, determined that even if the attorney general waited too long to raise the argument that Texas courts have no power to dissolve a same-sex marriage, if his argument was right, then the divorce would be void and challengeable. In his separate dissent, Justice Devine resolved the open question left in Justice Willett's dissent explaining that Texas law divests state courts of subject matter jurisdiction over same-sex proceedings.
Link to Opinion
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State v. Nicholas, 200 N.E.3d 268 (Ohio 2022)
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Ohio | 2022 | Criminal Justice, Juvenile Justice |
State:
Ohio
Year:
2022
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAfter the juvenile court transferred jurisdiction over the Defendant to that court's general, adult division, a jury found the Defendant guilty of aggravated murder and murder, both with firearm specifications, for the killing of his father's girlfriend when he was 14 years old. In his direct appeal, the Defendant argued that the juvenile court abused its discretion and violated his constitutional right to due process by transferring his case to the adult court, but the court of appeals rejected that argument and affirmed the convictions. The Defendant thereafter appealed again arguing that the appellate court did not consider the applicable standards of proof, including the Defendant's argument that the state has the burden of proof regarding nonamenability. The Supreme Court held that, for purposes of a discretionary bindover, the state has the burden of persuasion by a preponderance of the evidence on the issue of whether the juvenile is not amenable to rehabilitation in the juvenile system, but it need not produce affirmative evidence of nonamenability.
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Justice Vote Breakdown
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Summary of Case Context & Holding
After the juvenile court transferred jurisdiction over the Defendant to that court's general, adult division, a jury found the Defendant guilty of aggravated murder and murder, both with firearm specifications, for the killing of his father's girlfriend when he was 14 years old. In his direct appeal, the Defendant argued that the juvenile court abused its discretion and violated his constitutional right to due process by transferring his case to the adult court, but the court of appeals rejected that argument and affirmed the convictions. The Defendant thereafter appealed again arguing that the appellate court did not consider the applicable standards of proof, including the Defendant's argument that the state has the burden of proof regarding nonamenability. The Supreme Court held that, for purposes of a discretionary bindover, the state has the burden of persuasion by a preponderance of the evidence on the issue of whether the juvenile is not amenable to rehabilitation in the juvenile system, but it need not produce affirmative evidence of nonamenability.
Link to Opinion
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State v. Nimmer, 975 N.W.2d 598 (Wis. 2022)
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Wisconsin | 2022 | Criminal Justice, Police Misconduct and Bias |
State:
Wisconsin
Year:
2022
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was charged with possession of a firearm by a felon. He moved to suppress evidence obtained when officers stopped him without a warrant. The Supreme Court held that a Gunshot surveillance system, which detects gunshots via microphones placed in public areas, provided reasonable suspicion to make a warrantless investigatory stop of a defendant who walked away from a police car and reached with his hand on the left side of his body while turning that part of his body away from the police. The police considered the Defendant's behavior to be consistent with actions a person may take to conceal a weapon.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was charged with possession of a firearm by a felon. He moved to suppress evidence obtained when officers stopped him without a warrant. The Supreme Court held that a Gunshot surveillance system, which detects gunshots via microphones placed in public areas, provided reasonable suspicion to make a warrantless investigatory stop of a defendant who walked away from a police car and reached with his hand on the left side of his body while turning that part of his body away from the police. The police considered the Defendant's behavior to be consistent with actions a person may take to conceal a weapon.
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State v. Nissley, 387 P.3d 1256 (Ariz. 2017)
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Arizona | 2017 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2017
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingAfter a jury trial, Defendant was found guilty of reckless manslaughter due to drunk driving where he injured four and killed one pedestrian. Defendant appealed, arguing that the trial court erred when it denied his motion to suppress an involuntary blood sample taken for medical purposes when medical personnel rendered treatment against Defendant’s will. The court of appeals affirmed. The Supreme Court abrogated Arizona Supreme Court decision in State v. Cocio, 709 P.2d 1336 (Ariz. 1985). In Cocio, the Arizona Supreme Court held that a warrantless blood draw seizure is constitutionally permissible under the predecessor to § 28-1388(E) if (1) probable cause existed to believe that the person was driving under the influence; (2) exigent circumstances were present; and (3) the blood was drawn by medical personnel for a medical reason. In abrogating the decision, the Court dismissed the concern regarding exigency of alcohol leaving the bloodstream, holding that natural dissipation of alcohol in the bloodstream, by itself, does not establish a per se exigency that authorizes a warrantless blood test under the medical blood draw exception to the search-warrant requirement. The Court also held that, as a matter of first impression, other than when the defendant is incapable of providing consent, the State must show that the defendant freely and voluntarily consented to treatment to prove that a blood sample obtained under the medical blood draw exception was drawn in compliance with the defendant’s due process right to direct his or her own treatment. The Court remanded to the trial court to determine whether law enforcement lawfully obtained the blood sample.
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Justice Vote Breakdown
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Summary of Case Context & Holding
After a jury trial, Defendant was found guilty of reckless manslaughter due to drunk driving where he injured four and killed one pedestrian. Defendant appealed, arguing that the trial court erred when it denied his motion to suppress an involuntary blood sample taken for medical purposes when medical personnel rendered treatment against Defendant’s will. The court of appeals affirmed. The Supreme Court abrogated Arizona Supreme Court decision in State v. Cocio, 709 P.2d 1336 (Ariz. 1985). In Cocio, the Arizona Supreme Court held that a warrantless blood draw seizure is constitutionally permissible under the predecessor to § 28-1388(E) if (1) probable cause existed to believe that the person was driving under the influence; (2) exigent circumstances were present; and (3) the blood was drawn by medical personnel for a medical reason. In abrogating the decision, the Court dismissed the concern regarding exigency of alcohol leaving the bloodstream, holding that natural dissipation of alcohol in the bloodstream, by itself, does not establish a per se exigency that authorizes a warrantless blood test under the medical blood draw exception to the search-warrant requirement. The Court also held that, as a matter of first impression, other than when the defendant is incapable of providing consent, the State must show that the defendant freely and voluntarily consented to treatment to prove that a blood sample obtained under the medical blood draw exception was drawn in compliance with the defendant’s due process right to direct his or her own treatment. The Court remanded to the trial court to determine whether law enforcement lawfully obtained the blood sample.
Link to Opinion
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State v. Njango, 255 A.3d 1164 (N.J. 2021)
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New Jersey | 2021 | Criminal Justice, Access to Justice |
State:
New Jersey
Year:
2021
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant, who pled guilty to offenses including first-degree attempted murder, filed a petition for post-conviction relief, challenging the calculation of a number of service credits Defendant had at the time of the relevant sentencing and seeking reduction of the parole supervision period under the No Early Release Act (NERA). Defendant then filed a petition under the State’s Post-Conviction Relief Act, arguing that his release was delayed by the second sentencing court’s refusal to grant him the proper credits for time served, resulting in an additional year and seven months of imprisonment while on appeal. He asked that his parole period be reduced by that amount. The court denied the petition, and the Appellate Division affirmed. The Supreme Court rejected the State’s argument that the parole period could not be reduced due to public safety considerations or because it was specified in the NERA, noting that time spent in prison was at least as beneficial to public safety as time spent on parole. The Supreme Court further held that the fundamental fairness doctrine required Defendant not to be arbitrarily denied credit for time served in prison. Additionally, should Defendant not have his parole reduced by the excess time he spent in prison, he would end up serving a unitary sentence in excess of the sentence he actually received. Holding that “parole is the legal equivalent of imprisonment,” the Supreme Court reversed the Appellate Division’s judgment and remanded to the state parole board to recalculate Defendant's parole period after giving him credit for the excess time in prison.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant, who pled guilty to offenses including first-degree attempted murder, filed a petition for post-conviction relief, challenging the calculation of a number of service credits Defendant had at the time of the relevant sentencing and seeking reduction of the parole supervision period under the No Early Release Act (NERA). Defendant then filed a petition under the State’s Post-Conviction Relief Act, arguing that his release was delayed by the second sentencing court’s refusal to grant him the proper credits for time served, resulting in an additional year and seven months of imprisonment while on appeal. He asked that his parole period be reduced by that amount. The court denied the petition, and the Appellate Division affirmed. The Supreme Court rejected the State’s argument that the parole period could not be reduced due to public safety considerations or because it was specified in the NERA, noting that time spent in prison was at least as beneficial to public safety as time spent on parole. The Supreme Court further held that the fundamental fairness doctrine required Defendant not to be arbitrarily denied credit for time served in prison. Additionally, should Defendant not have his parole reduced by the excess time he spent in prison, he would end up serving a unitary sentence in excess of the sentence he actually received. Holding that “parole is the legal equivalent of imprisonment,” the Supreme Court reversed the Appellate Division’s judgment and remanded to the state parole board to recalculate Defendant's parole period after giving him credit for the excess time in prison.
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State v. Noli, 529 P.3d 813 (Mont. 2023)
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Montana | 2023 | Criminal Justice, Police Misconduct and Bias |
State:
Montana
Year:
2023
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThis case arises out of an investigative traffic stop. The trooper made Defendant come back to his vehicle, where he questioned the Defendant about matters unrelated to the traffic stop and questioned the car passenger as well. After almost 20 minutes of questioning, he asked the Defendant if she had drugs in the car and if he could search her car. Defendant eventually agreed to the search and drugs were discovered in her car. The Defendant was arrested. Defendant asserted that the district court erroneously denied her motion to suppress the drug evidence discovered as the fruit of a warrantless investigative traffic violation stop. The Court agreed and reversed. The Court noted that in the absence of some specific officer-articulated facts or inferences that are objectively indicative of some particular criminal activity, merely inconsistent accounts of a person's conduct or plans, unusually nervous behavior, not making eye contact with police, a messy vehicle interior, use of a highway commonly used for drug trafficking, are insufficient alone, individually or collectively, to support an objectively reasonable particularized suspicion of criminal activity. The Court reversed Defendant's drug related conviction and held that the district court erred in denying Defendant's motion to suppress evidence because the trooper unlawfully detoured and measurably and unlawfully extended the scope and duration of the traffic violation enforcement purpose and mission of the stop to conduct a wholly unrelated illegal drug investigation without an objectively reasonable particularized suspicion that Defendant was transporting illegal drugs as suspected. The Court held that authority for the seizure ends when tasks tied to the traffic infraction are or reasonably should have been completed and the fact that the trooper later found illegal drug evidence in the vehicle has no legal bearing on whether he had a legal justification to detain Defendant on a traffic violation stop long enough to extensively question her to try to confirm that undeveloped suspicion.
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Justice Vote Breakdown
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Summary of Case Context & Holding
This case arises out of an investigative traffic stop. The trooper made Defendant come back to his vehicle, where he questioned the Defendant about matters unrelated to the traffic stop and questioned the car passenger as well. After almost 20 minutes of questioning, he asked the Defendant if she had drugs in the car and if he could search her car. Defendant eventually agreed to the search and drugs were discovered in her car. The Defendant was arrested. Defendant asserted that the district court erroneously denied her motion to suppress the drug evidence discovered as the fruit of a warrantless investigative traffic violation stop. The Court agreed and reversed. The Court noted that in the absence of some specific officer-articulated facts or inferences that are objectively indicative of some particular criminal activity, merely inconsistent accounts of a person's conduct or plans, unusually nervous behavior, not making eye contact with police, a messy vehicle interior, use of a highway commonly used for drug trafficking, are insufficient alone, individually or collectively, to support an objectively reasonable particularized suspicion of criminal activity. The Court reversed Defendant's drug related conviction and held that the district court erred in denying Defendant's motion to suppress evidence because the trooper unlawfully detoured and measurably and unlawfully extended the scope and duration of the traffic violation enforcement purpose and mission of the stop to conduct a wholly unrelated illegal drug investigation without an objectively reasonable particularized suspicion that Defendant was transporting illegal drugs as suspected. The Court held that authority for the seizure ends when tasks tied to the traffic infraction are or reasonably should have been completed and the fact that the trooper later found illegal drug evidence in the vehicle has no legal bearing on whether he had a legal justification to detain Defendant on a traffic violation stop long enough to extensively question her to try to confirm that undeveloped suspicion.
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State v. Nunez-Diaz, 444 P.3d 250 (Ariz. 2019)
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Arizona | 2019 | Immigration, Deportation, Criminal Justice, Access to Justice |
State:
Arizona
Year:
2019
Topics:
Immigration, Deportation, Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court found that Hector Sebastion Nunez-Diaz, an undocumented immigrant, received ineffective assistance of counsel when he entered a guilty plea resulting in his mandatory deportation. Nunez-Diaz’s plea resulted in a conviction that falls under 8 U.S.C. § 1227(a)(2)(B). This type of conviction renders a noncitizen, other than a lawful permanent resident, ineligible for discretionary relief from removal, and would permanently prevent the individual from ever returning to the United States. The trial court determined that competent counsel “could have easily explained the adverse immigration consequences of the plea" and that there was “overwhelming evidence” that counsel’s assistance was constitutionally deficient. At oral argument in the Supreme Court, the State conceded that plea counsel’s assistance fell below an objective standard of reasonableness. Because Nunez-Diaz suffered severe and mandatory consequences (including a permanent bar from reentry) as a result of the plea he entered due to counsel’s deficient advice, the Court held that he received ineffective assistance of counsel justifying post-conviction relief.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court found that Hector Sebastion Nunez-Diaz, an undocumented immigrant, received ineffective assistance of counsel when he entered a guilty plea resulting in his mandatory deportation. Nunez-Diaz’s plea resulted in a conviction that falls under 8 U.S.C. § 1227(a)(2)(B). This type of conviction renders a noncitizen, other than a lawful permanent resident, ineligible for discretionary relief from removal, and would permanently prevent the individual from ever returning to the United States. The trial court determined that competent counsel “could have easily explained the adverse immigration consequences of the plea" and that there was “overwhelming evidence” that counsel’s assistance was constitutionally deficient. At oral argument in the Supreme Court, the State conceded that plea counsel’s assistance fell below an objective standard of reasonableness. Because Nunez-Diaz suffered severe and mandatory consequences (including a permanent bar from reentry) as a result of the plea he entered due to counsel’s deficient advice, the Court held that he received ineffective assistance of counsel justifying post-conviction relief.
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State v. Nyema, 267 A.3d 449 (N. J. 2022)
State v. Myers, 267 A.3d 449 (N.J. 2022)
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New Jersey | 2022 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2022
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPolice dispatch described suspects in a robbery as "two Black males, one with a handgun." An officer stopped a vehicle close to the location of the robbery because he observed three Black males in the car, stopping them on the sole basis of their race and gender and the fact that they did not react to the spotlight he shone into the car. After stopping the car, the officer learned that the vehicle had been stolen so he placed the occupants (including Nyema and Myers) under arrest. After searching the car pursuant to this arrest, he found various evidence relevant to the robbery (including a handgun and cash equivalent to the amount stolen). The Defendants, Nyema and Myers, jointly moved to suppress the physical evidence seized from the stop. The trial court found the initial stop was supported by reasonable and articulable suspicion. The issue presented to the New Jersey Supreme Court was whether the stop of the vehicle was supported by reasonable and articulable suspicion. The Supreme Court held that the police dispatch alert stating that two Black males were suspects for a convenience-store robbery that had just occurred did not provide the officer with reasonable suspicion for an investigatory stop of a vehicle with three Black males inside. The Court reasoned that race and sex can support reasonable and articulable suspicion when taken together with other, discrete factors such as height, weight, age, clothing, or mode of transportation. However, the only information the officer possessed at the time of the stop was the race and sex of the suspects, with no further descriptors. That information, which effectively placed every single Black male in the area under the veil of suspicion, was insufficient to justify the stop of the vehicle and therefore did not withstand constitutional scrutiny. The Supreme Court affirmed the Appellate Division's ruling that the stop was not based on reasonable and articulable suspicion.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Police dispatch described suspects in a robbery as "two Black males, one with a handgun." An officer stopped a vehicle close to the location of the robbery because he observed three Black males in the car, stopping them on the sole basis of their race and gender and the fact that they did not react to the spotlight he shone into the car. After stopping the car, the officer learned that the vehicle had been stolen so he placed the occupants (including Nyema and Myers) under arrest. After searching the car pursuant to this arrest, he found various evidence relevant to the robbery (including a handgun and cash equivalent to the amount stolen). The Defendants, Nyema and Myers, jointly moved to suppress the physical evidence seized from the stop. The trial court found the initial stop was supported by reasonable and articulable suspicion. The issue presented to the New Jersey Supreme Court was whether the stop of the vehicle was supported by reasonable and articulable suspicion. The Supreme Court held that the police dispatch alert stating that two Black males were suspects for a convenience-store robbery that had just occurred did not provide the officer with reasonable suspicion for an investigatory stop of a vehicle with three Black males inside. The Court reasoned that race and sex can support reasonable and articulable suspicion when taken together with other, discrete factors such as height, weight, age, clothing, or mode of transportation. However, the only information the officer possessed at the time of the stop was the race and sex of the suspects, with no further descriptors. That information, which effectively placed every single Black male in the area under the veil of suspicion, was insufficient to justify the stop of the vehicle and therefore did not withstand constitutional scrutiny. The Supreme Court affirmed the Appellate Division's ruling that the stop was not based on reasonable and articulable suspicion.
Link to Opinion
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State v. Oldroyd, 869 S.E.2d 193 (N.C. 2022)
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North Carolina | 2022 | Criminal Justice |
State:
North Carolina
Year:
2022
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court held that Defendant's constitutional right to be protected from double jeopardy was not violated by an indictment that did not provide the legal name of the victims of the alleged offense. The Supreme Court reasoned that an indictment need only satisfy statutory requirements and constitutional purposes of criminal pleadings. In particular, the purpose of the indictment is to allow the Defendant to identify the event in question such that he can prepare a defense and be protected from double jeopardy. The Supreme Court found that the indictment was sufficient to protect the Defendant from double jeopardy if it set forth the facts supporting each element of the crime charged with enough "exactitude." In this case, the indictment for attempted armed robbery and conspiracy to commit armed robbery named "employees of the Huddle House located at 1538 NC Highway 67, Jonesville, North Carolina" as the victims of the armed robbery charges. The Defendant pled guilty to the charges at trial then moved for relief from the charges, arguing that the indictment was insufficient to protect him from double jeopardy. The trial court denied this motion but on appeal the court of appeals agreed with the Defendant's argument and vacated the lower court's judgement. The Supreme Court then reversed the appellate court decision and held that the indictment was sufficiently specific to protect the Defendant "from being twice put in jeopardy for the alleged commission of the same offense" because the description of the victims was sufficient to give the Defendant notice of the event or transgression that he was expected to defend, notwithstanding that the indictment did not include the victim's legal names.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court held that Defendant's constitutional right to be protected from double jeopardy was not violated by an indictment that did not provide the legal name of the victims of the alleged offense. The Supreme Court reasoned that an indictment need only satisfy statutory requirements and constitutional purposes of criminal pleadings. In particular, the purpose of the indictment is to allow the Defendant to identify the event in question such that he can prepare a defense and be protected from double jeopardy. The Supreme Court found that the indictment was sufficient to protect the Defendant from double jeopardy if it set forth the facts supporting each element of the crime charged with enough "exactitude." In this case, the indictment for attempted armed robbery and conspiracy to commit armed robbery named "employees of the Huddle House located at 1538 NC Highway 67, Jonesville, North Carolina" as the victims of the armed robbery charges. The Defendant pled guilty to the charges at trial then moved for relief from the charges, arguing that the indictment was insufficient to protect him from double jeopardy. The trial court denied this motion but on appeal the court of appeals agreed with the Defendant's argument and vacated the lower court's judgement. The Supreme Court then reversed the appellate court decision and held that the indictment was sufficiently specific to protect the Defendant "from being twice put in jeopardy for the alleged commission of the same offense" because the description of the victims was sufficient to give the Defendant notice of the event or transgression that he was expected to defend, notwithstanding that the indictment did not include the victim's legal names.
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State v. Ortiz-Mondragon, 866 N.W.2d 717 (Wis. 2015)
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Wisconsin | 2015 | Criminal Justice, Access to Justice |
State:
Wisconsin
Year:
2015
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant filed a post-conviction motion to withdraw his guilty plea on grounds of ineffective assistance of counsel. The Supreme Court held that: (1) counsel was not required to inform non-citizen Defendant that his guilty plea to several domestic abuse related charges would result in mandatory deportation on grounds that they constituted crimes of moral turpitude; and (2) counsel did not perform deficiently by failing to further research immigration consequences of plea agreement. Consequently, the motion to withdraw the guilty plea was denied.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant filed a post-conviction motion to withdraw his guilty plea on grounds of ineffective assistance of counsel. The Supreme Court held that: (1) counsel was not required to inform non-citizen Defendant that his guilty plea to several domestic abuse related charges would result in mandatory deportation on grounds that they constituted crimes of moral turpitude; and (2) counsel did not perform deficiently by failing to further research immigration consequences of plea agreement. Consequently, the motion to withdraw the guilty plea was denied.
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State v. Patrick, 172 N.E.3d 952 (Ohio 2020)
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Ohio | 2020 | Criminal Justice, Juvenile Justice, Death Penalty |
State:
Ohio
Year:
2020
Topics:
Criminal Justice, Juvenile Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Defendant was charged with multiple charges, including murder, stemming from a shooting. He was bound over to be tried as an adult and plead guilty to murder and other charges. Prior to sentencing, he moved to set aside his guilty plea, but the trial court denied the motion and sentenced him to an aggregate sentence of life imprisonment with parole eligibility after 16 years and ultimately received parole eligibility after 33 years after losing an appeal. On appeal, the Defendant argued that the trial court had failed to consider his youth when it imposed a life sentence and therefore his sentence violated the Eighth and Fourteenth Amendments to the U.S. Constitution. The Supreme Court held that a trial court must consider the age of a defendant during the crime and his or her attendant characteristics before imposing a life sentence, even if that sentence includes eligibility for parole, and such consideration must be articulated in the sentencing record.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Defendant was charged with multiple charges, including murder, stemming from a shooting. He was bound over to be tried as an adult and plead guilty to murder and other charges. Prior to sentencing, he moved to set aside his guilty plea, but the trial court denied the motion and sentenced him to an aggregate sentence of life imprisonment with parole eligibility after 16 years and ultimately received parole eligibility after 33 years after losing an appeal. On appeal, the Defendant argued that the trial court had failed to consider his youth when it imposed a life sentence and therefore his sentence violated the Eighth and Fourteenth Amendments to the U.S. Constitution. The Supreme Court held that a trial court must consider the age of a defendant during the crime and his or her attendant characteristics before imposing a life sentence, even if that sentence includes eligibility for parole, and such consideration must be articulated in the sentencing record.
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State v. Peoples, 378 P.3d 421 (Ariz. 2016)
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Arizona | 2016 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2016
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was charged with necrophilia and two counts of sexual assault. Defendant moved to suppress evidence of a video taken with his cell phone that he left in the victim’s apartment where he was an overnight guest, contending that the warrantless search of his phone was unconstitutional. The trial court granted Defendant’s motion and suppressed the video and statements Defendant made to the police about that video, holding in reliance on Riley v. California, 573 U.S. 373 (2014), which found that a person has a legitimate expectation of privacy in their cell phone, the evidence resulted from an illegal search. The court of appeals reversed, ruling that the warrantless search of the phone was permissible because Defendant did not have a reasonable expectation of privacy in either the victim’s apartment or his cell phone. The Supreme Court held that (1) Defendant had a reasonable expectation of privacy in his phone; (2) as an overnight guest, Defendant had a legitimate expectation of privacy in the apartment; and (3) no exception to the warrant requirement existed, and therefore, the good-faith exception to the exclusionary rule did not apply. Relying on Riley, the Arizona Supreme Court reasoned that Defendant did not terminate his guest status when he left the searched apartment but instead maintained a reasonable expectation of privacy in the apartment until he was able to conclude his stay by retrieving his phone.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was charged with necrophilia and two counts of sexual assault. Defendant moved to suppress evidence of a video taken with his cell phone that he left in the victim’s apartment where he was an overnight guest, contending that the warrantless search of his phone was unconstitutional. The trial court granted Defendant’s motion and suppressed the video and statements Defendant made to the police about that video, holding in reliance on Riley v. California, 573 U.S. 373 (2014), which found that a person has a legitimate expectation of privacy in their cell phone, the evidence resulted from an illegal search. The court of appeals reversed, ruling that the warrantless search of the phone was permissible because Defendant did not have a reasonable expectation of privacy in either the victim’s apartment or his cell phone. The Supreme Court held that (1) Defendant had a reasonable expectation of privacy in his phone; (2) as an overnight guest, Defendant had a legitimate expectation of privacy in the apartment; and (3) no exception to the warrant requirement existed, and therefore, the good-faith exception to the exclusionary rule did not apply. Relying on Riley, the Arizona Supreme Court reasoned that Defendant did not terminate his guest status when he left the searched apartment but instead maintained a reasonable expectation of privacy in the apartment until he was able to conclude his stay by retrieving his phone.
Link to Opinion
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State v. Peraza, 259 So. 3d 728 (Fla. 2018)
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Florida | 2018 | Criminal Justice, Police Misconduct and Bias |
State:
Florida
Year:
2018
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court considers whether law enforcement officers can invoke the Stand Your Ground law (immunity from criminal prosecution and civil action for justifiable use of deadly force upon the reasonable belief that such force is necessary to prevent imminent death or great bodily harm to himself or herself or another) for immunity. Jermaine McBean purchased a rifle from a pawn shop and a neighbor called the police to report that McBean appeared distraught. Officer Peraza appeared on scene with other officers and asked McBean to stop walking. McBean did not stop. McBean brought the rifle over his head and pointed the weapon at the officers (though one witness testified that McBean did not point the weapon at the officers). Peraza fired his gun three times and killed McBean. Peraza was indicted for manslaughter, but the case was dismissed based upon Stand Your Ground immunity. The State appealed, claiming that officers are not eligible to assert Stand Your Ground immunity because they are already provided another statutory defense, which involves the justifiable use of force when making a lawful arrest. Using a plain meaning analysis of the Stand Your Ground law, the Supreme Court determined that law enforcement officers can rely on the Stand Your Ground Law for immunity, even when the use of force occurred during the course of making a lawful arrest.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court considers whether law enforcement officers can invoke the Stand Your Ground law (immunity from criminal prosecution and civil action for justifiable use of deadly force upon the reasonable belief that such force is necessary to prevent imminent death or great bodily harm to himself or herself or another) for immunity. Jermaine McBean purchased a rifle from a pawn shop and a neighbor called the police to report that McBean appeared distraught. Officer Peraza appeared on scene with other officers and asked McBean to stop walking. McBean did not stop. McBean brought the rifle over his head and pointed the weapon at the officers (though one witness testified that McBean did not point the weapon at the officers). Peraza fired his gun three times and killed McBean. Peraza was indicted for manslaughter, but the case was dismissed based upon Stand Your Ground immunity. The State appealed, claiming that officers are not eligible to assert Stand Your Ground immunity because they are already provided another statutory defense, which involves the justifiable use of force when making a lawful arrest. Using a plain meaning analysis of the Stand Your Ground law, the Supreme Court determined that law enforcement officers can rely on the Stand Your Ground Law for immunity, even when the use of force occurred during the course of making a lawful arrest.
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State v. Perez-Gutieriez, 548 P.3d 1102 (Ariz. 2024)
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Arizona | 2024 | Criminal Justice, Access to Justice |
State:
Arizona
Year:
2024
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of sexual conduct with a minor. The trial court sentenced Defendant to two 20 year terms of imprisonment for the first two counts and one-year sentences for the remaining six counts, all to be served consecutively. Per A.R.S. § 13-711(A), the court had discretion to impose the remaining sentences consecutively or concurrently but failed to state on the record the reason for its determination. Defendant appealed, and the court of appeals ruled in his favor. Applying the Arizona Supreme Court's State v. Anzivino, 716 P.2d 50 (Ariz. Ct. App. 1985), and State v. Harrison, 985 P.2d 486 (Ariz. 1985), the court of appeals held that a judge must "articulate at sentencing the factors he or she considered, and (2) explain how those factors led to the sentence he or she imposed . . . if a judge fails to substantially comply with these requirements, the case must be remanded for the trial court to satisfy § 13-711(A)." However, the Arizona Supreme Court disagreed. Abrogating their previous decisions in Anzivino and Harrison, that allowed limited remand but required resentencing, the Supreme Court held that the appropriate remedy for a sentencing court's failure to state on the record its reasoning for its sentencing decision was a remand to the trial court to place reasons on the record. The Supreme Court explained that a violation of § 13-711(A) is an administrative error that a trial court can correct without requiring the case to be resentenced.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of sexual conduct with a minor. The trial court sentenced Defendant to two 20 year terms of imprisonment for the first two counts and one-year sentences for the remaining six counts, all to be served consecutively. Per A.R.S. § 13-711(A), the court had discretion to impose the remaining sentences consecutively or concurrently but failed to state on the record the reason for its determination. Defendant appealed, and the court of appeals ruled in his favor. Applying the Arizona Supreme Court's State v. Anzivino, 716 P.2d 50 (Ariz. Ct. App. 1985), and State v. Harrison, 985 P.2d 486 (Ariz. 1985), the court of appeals held that a judge must "articulate at sentencing the factors he or she considered, and (2) explain how those factors led to the sentence he or she imposed . . . if a judge fails to substantially comply with these requirements, the case must be remanded for the trial court to satisfy § 13-711(A)." However, the Arizona Supreme Court disagreed. Abrogating their previous decisions in Anzivino and Harrison, that allowed limited remand but required resentencing, the Supreme Court held that the appropriate remedy for a sentencing court's failure to state on the record its reasoning for its sentencing decision was a remand to the trial court to place reasons on the record. The Supreme Court explained that a violation of § 13-711(A) is an administrative error that a trial court can correct without requiring the case to be resentenced.
Link to Opinion
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State v. Pierre, 127 A.3d 1260 (2015)
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New Jersey | 2015 | Criminal Justice, Access to Justice |
State:
New Jersey
Year:
2015
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingIn 1996, Defendant Duquene Pierre was convicted of first-degree murder, first-degree felony murder, and several other offenses arising from a fatal shooting. The appeal arises from the denial of Defendant's application for post-conviction relief (PCR), based on a claim of ineffective assistance of counsel at trial. Specifically, Defendant presented various pieces of evidence that would have supported his alibi that he was in Florida in the days that followed the shooting. However, Defendant's trial counsel did not contact the relevant parties to ascertain their knowledge of those facts. The PCR court denied Defendant's PCR application, and the Appellate Division affirmed. The Supreme Court held that Defendant was denied the effective assistance of counsel guaranteed by the Sixth Amendment to the U.S. Constitution and the New Jersey Constitution. Specifically, the Supreme Court found that the record before the PCR court established that Defendant's trial counsel did not present evidence that would have both rebutted the State's theory and supported Defendant's alibi and, in light of the inconclusive evidence presented against Defendant at trial, Defendant demonstrated that counsel's errors prejudiced the defense and denied him a fair trial.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 1996, Defendant Duquene Pierre was convicted of first-degree murder, first-degree felony murder, and several other offenses arising from a fatal shooting. The appeal arises from the denial of Defendant's application for post-conviction relief (PCR), based on a claim of ineffective assistance of counsel at trial. Specifically, Defendant presented various pieces of evidence that would have supported his alibi that he was in Florida in the days that followed the shooting. However, Defendant's trial counsel did not contact the relevant parties to ascertain their knowledge of those facts. The PCR court denied Defendant's PCR application, and the Appellate Division affirmed. The Supreme Court held that Defendant was denied the effective assistance of counsel guaranteed by the Sixth Amendment to the U.S. Constitution and the New Jersey Constitution. Specifically, the Supreme Court found that the record before the PCR court established that Defendant's trial counsel did not present evidence that would have both rebutted the State's theory and supported Defendant's alibi and, in light of the inconclusive evidence presented against Defendant at trial, Defendant demonstrated that counsel's errors prejudiced the defense and denied him a fair trial.
Link to Opinion
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State v. Poole, 297 So. 3d 487 (Fla. 2020)
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Florida | 2020 | Criminal Justice, Death Penalty, Access to Justice |
State:
Florida
Year:
2020
Topics:
Criminal Justice, Death Penalty, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPoole was convicted of the first-degree murder, attempted first-degree murder, armed burglary, sexual battery, and armed robbery. Poole was subsequently sentenced to death in 2011. On April 8, 2016, Poole filed his initial postconviction motion raising two issues on appeal: (i) counsel was ineffective for conceding that Poole committed the nonhomicide offenses; and (ii) Poole is entitled to resentencing because the jury did not make the findings required by Hurst v. State, 202 So. 3d 40 (Fla. 2016) (holding that before the judge may consider imposing a sentence of death, the jury in a capital case must unanimously and expressly find all the aggravating factors that were proven beyond a reasonable doubt, unanimously find that the aggravating factors are sufficient to impose death, unanimously find that the aggravating factors outweigh the mitigating factors, and unanimously recommend a sentence of death). The trial court set aside the sentence and ordered a new penalty phase after finding the sentence to have been imposed in violation of the United States and Florida Constitutions as interpreted and applied in Hurst. Following an evidentiary hearing, the trial court denied Poole's claim that counsel was ineffective for conceding guilt on the nonhomicide offenses. The State appealed from the postconviction order setting aside Poole's 2011 death sentence, arguing that Poole suffered no constitutional deprivation in his sentencing proceeding and requesting that the Supreme Court reexamine and partially recede from Hurst. Finding that neither the United States nor the Florida Constitution requires a unanimous jury recommendation of death, the Supreme Court receded from Hurst "except to the extent that it held that a jury must unanimously find the existence of a statutory aggravating circumstance beyond a reasonable doubt" and concluded that there was no Hurst violation where the jury found Poole guilty of a contemporaneous robbery, among other qualifying offenses.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Poole was convicted of the first-degree murder, attempted first-degree murder, armed burglary, sexual battery, and armed robbery. Poole was subsequently sentenced to death in 2011. On April 8, 2016, Poole filed his initial postconviction motion raising two issues on appeal: (i) counsel was ineffective for conceding that Poole committed the nonhomicide offenses; and (ii) Poole is entitled to resentencing because the jury did not make the findings required by Hurst v. State, 202 So. 3d 40 (Fla. 2016) (holding that before the judge may consider imposing a sentence of death, the jury in a capital case must unanimously and expressly find all the aggravating factors that were proven beyond a reasonable doubt, unanimously find that the aggravating factors are sufficient to impose death, unanimously find that the aggravating factors outweigh the mitigating factors, and unanimously recommend a sentence of death). The trial court set aside the sentence and ordered a new penalty phase after finding the sentence to have been imposed in violation of the United States and Florida Constitutions as interpreted and applied in Hurst. Following an evidentiary hearing, the trial court denied Poole's claim that counsel was ineffective for conceding guilt on the nonhomicide offenses. The State appealed from the postconviction order setting aside Poole's 2011 death sentence, arguing that Poole suffered no constitutional deprivation in his sentencing proceeding and requesting that the Supreme Court reexamine and partially recede from Hurst. Finding that neither the United States nor the Florida Constitution requires a unanimous jury recommendation of death, the Supreme Court receded from Hurst "except to the extent that it held that a jury must unanimously find the existence of a statutory aggravating circumstance beyond a reasonable doubt" and concluded that there was no Hurst violation where the jury found Poole guilty of a contemporaneous robbery, among other qualifying offenses.
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State v. Porter, 491 P.3d 1100 (Ariz. 2021)
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Arizona | 2021 | Criminal Justice, Access to Justice |
State:
Arizona
Year:
2021
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDuring jury selection in Keyaira Porter’s trial for aggravated assault and resisting arrest, the prosecutor used peremptory strikes to remove the only two African American prospective jurors. Porter raised a Batson challenge, arguing racial discrimination. Batson v. Kentucky, 476 U.S. 79 (1986). The trial court denied the challenge, finding the prosecutor’s race-neutral reasons—such as a juror’s family criminal history and prior jury service—were reasonable. The Arizona Supreme Court held that trial courts are not required to make express credibility findings on demeanor-based justifications when a valid, non-demeanor-based reason is also provided and there is no evidence of pretext. The Court affirmed the trial court’s ruling, concluding that the Batson challenge was properly denied.
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Justice Vote Breakdown
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Summary of Case Context & Holding
During jury selection in Keyaira Porter’s trial for aggravated assault and resisting arrest, the prosecutor used peremptory strikes to remove the only two African American prospective jurors. Porter raised a Batson challenge, arguing racial discrimination. Batson v. Kentucky, 476 U.S. 79 (1986). The trial court denied the challenge, finding the prosecutor’s race-neutral reasons—such as a juror’s family criminal history and prior jury service—were reasonable. The Arizona Supreme Court held that trial courts are not required to make express credibility findings on demeanor-based justifications when a valid, non-demeanor-based reason is also provided and there is no evidence of pretext. The Court affirmed the trial court’s ruling, concluding that the Batson challenge was properly denied.
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State v. Porter, 80 A.3d 732 (N.J.2013)
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New Jersey | 2013 | Criminal Justice, Access to Justice |
State:
New Jersey
Year:
2013
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant Oscar Porter appealed an order of the Appellate Division affirming the denial of his post-conviction relief (PCR) petition without an evidentiary hearing. Defendant challenged his convictions for attempted murder, armed robbery, conspiracy to commit armed robbery, and aggravated assault. In his PCR petition, Defendant alleged ineffective assistance by trial counsel for failing to investigate an alibi defense, failing to present two witnesses to impeach the credibility of the State's principal witnesses, and failing to convey a plea offer to Defendant. Because Defendant's claim raises material issues of disputed facts, the Court reversed the judgment of the Appellate Division and remanded the case to the Law Division for an evidentiary hearing regarding the failure to investigate the alibi defense.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant Oscar Porter appealed an order of the Appellate Division affirming the denial of his post-conviction relief (PCR) petition without an evidentiary hearing. Defendant challenged his convictions for attempted murder, armed robbery, conspiracy to commit armed robbery, and aggravated assault. In his PCR petition, Defendant alleged ineffective assistance by trial counsel for failing to investigate an alibi defense, failing to present two witnesses to impeach the credibility of the State's principal witnesses, and failing to convey a plea offer to Defendant. Because Defendant's claim raises material issues of disputed facts, the Court reversed the judgment of the Appellate Division and remanded the case to the Law Division for an evidentiary hearing regarding the failure to investigate the alibi defense.
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State v. Powell, 880 S.E.2d 189 (Ga. 2022)
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Georgia | 2022 | Criminal Justice, Juvenile Justice |
State:
Georgia
Year:
2022
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe Supreme Court held that in a murder case, the trial court did not err in determining that Defendant's statements were involuntary, since Defendant was 15 years old, was consistently told she was merely a witness, Defendant was never informed that her statements could be used against her at trial, or she could go to jail based on what she told detectives. The trial court partially suppressed Defendant's statements, finding that she did not knowingly and voluntarily make a statement as a matter of constitutional due process, and the State appealed. The Supreme Court affirmed the trial court's ruling. The detective testified that Defendant was not in custody for any of her interviews and was free to leave, that she was not read her Miranda rights at any time, and that she was never informed that her interviews were being recorded. In addition to applying the nine Riley factors in order to determine whether a juvenile voluntarily waived his or her Miranda rights during a custodial interview, the Supreme Court has also in prior cases relied on its factors in evaluating more general due process voluntariness cases for juveniles. The nine Riley factors are: "(1) age of the accused; (2) education of the accused; (3) knowledge of the accused as to both the substance of the charge . . . and the nature of [her] rights to consult with an attorney and remain silent; (4) whether the accused is held incommunicado or allowed to consult with relatives, friends or an attorney; (5) whether the accused was interrogated before or after formal charges had been filed; (6) methods used in interrogations; (7) length of interrogations; (8) whether vel non the accused refused to voluntarily give statements on prior occasions; and (9) whether the accused has repudiated an extra judicial statement at a later date." Riley v. State, 226 S.Ed.2d 922, 926 (Ga. 1976). The record shows that the detective did not ask Defendant directly whether she wanted to talk to him or whether she wanted to do so without a lawyer, but rather directed all discussions of Defendant's constitutional rights to her mother. Accordingly, the Supreme Court explained that the trial court did not err in finding that the detective incorrectly advised Defendant that only her mother could invoke Defendant's right to counsel.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The Supreme Court held that in a murder case, the trial court did not err in determining that Defendant's statements were involuntary, since Defendant was 15 years old, was consistently told she was merely a witness, Defendant was never informed that her statements could be used against her at trial, or she could go to jail based on what she told detectives. The trial court partially suppressed Defendant's statements, finding that she did not knowingly and voluntarily make a statement as a matter of constitutional due process, and the State appealed. The Supreme Court affirmed the trial court's ruling. The detective testified that Defendant was not in custody for any of her interviews and was free to leave, that she was not read her Miranda rights at any time, and that she was never informed that her interviews were being recorded. In addition to applying the nine Riley factors in order to determine whether a juvenile voluntarily waived his or her Miranda rights during a custodial interview, the Supreme Court has also in prior cases relied on its factors in evaluating more general due process voluntariness cases for juveniles. The nine Riley factors are: "(1) age of the accused; (2) education of the accused; (3) knowledge of the accused as to both the substance of the charge . . . and the nature of [her] rights to consult with an attorney and remain silent; (4) whether the accused is held incommunicado or allowed to consult with relatives, friends or an attorney; (5) whether the accused was interrogated before or after formal charges had been filed; (6) methods used in interrogations; (7) length of interrogations; (8) whether vel non the accused refused to voluntarily give statements on prior occasions; and (9) whether the accused has repudiated an extra judicial statement at a later date." Riley v. State, 226 S.Ed.2d 922, 926 (Ga. 1976). The record shows that the detective did not ask Defendant directly whether she wanted to talk to him or whether she wanted to do so without a lawyer, but rather directed all discussions of Defendant's constitutional rights to her mother. Accordingly, the Supreme Court explained that the trial court did not err in finding that the detective incorrectly advised Defendant that only her mother could invoke Defendant's right to counsel.
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State v. Poyson, 475 P.3d 293 (Ariz. 2020)
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Arizona | 2020 | Criminal Justice, Death Penalty |
State:
Arizona
Year:
2020
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of three counts of first-degree murder. During sentencing, the trial court found three aggravating factors beyond a reasonable doubt and only one mitigating factor. The trial court sentenced Defendant to death. On review, the Supreme Court found additional mitigating factors of age, family support, and potential for rehabilitation, but nonetheless upheld Defendant's sentence. Defendant later filed a petition for a writ of habeas corpus, which the federal district court denied. The Ninth Circuit reversed and granted relief, concluding that habeas relief was warranted because the Supreme Court erred in its independent review of the death sentences when considering Defendant's mitigation evidence. The Supreme Court granted the State's motion to conduct a new independent review and affirmed, holding that the mitigating evidence was not sufficient to warrant leniency in light of the three aggravators proven by the State.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of three counts of first-degree murder. During sentencing, the trial court found three aggravating factors beyond a reasonable doubt and only one mitigating factor. The trial court sentenced Defendant to death. On review, the Supreme Court found additional mitigating factors of age, family support, and potential for rehabilitation, but nonetheless upheld Defendant's sentence. Defendant later filed a petition for a writ of habeas corpus, which the federal district court denied. The Ninth Circuit reversed and granted relief, concluding that habeas relief was warranted because the Supreme Court erred in its independent review of the death sentences when considering Defendant's mitigation evidence. The Supreme Court granted the State's motion to conduct a new independent review and affirmed, holding that the mitigating evidence was not sufficient to warrant leniency in light of the three aggravators proven by the State.
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State v. Primous, 394 P.3d 646 (Ariz. 2017)
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Arizona | 2017 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2017
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingThe police conducted a pat-down search of Defendant based on the dangerousness of the area and the flight of one of Defendant’s companions. As a result of the pat down, the police found marijuana, and Defendant was charged with misdemeanor possession of marijuana. Defendant moved to suppress the findings from the pat-down search as a violation of his Fourth Amendment rights. The trial court denied Defendant’s motion to suppress, concluding that the search was proper. The court of appeals affirmed. The Supreme Court of Arizona held that under the totality of the circumstances, the police did not have an individualized reasonable suspicion that Defendant was engaged in criminal activity and that Defendant was armed and dangerous sufficient to justify the pat-down search. The Court contrasted this case with Illinois v. Wardlow, 528 U.S. 119 (2000), where the U.S. Supreme Court sustained a frisk by police officers who were patrolling an area known for heavy narcotics trafficking where the defendant fled upon seeing the officers, holding that "ample suspicion that the defendant was engaged in criminal activity and was armed and dangerous arose not only from his presence in a high-crime area, but also 'his unprovoked flight upon noticing the police.'" By contrast, the question before the Arizona Supreme Court was whether reasonable suspicion justified frisking Defendant not because of anything he did or said but because someone else with whom he was conversing fled when police approached. Although the dangerousness of the area and the flight of the companion were relevant factors, the Court found that they were not enough to justify the search. Accordingly, the lower courts' holdings on Defendant's motion to suppress were reversed, and Defendant's conviction and probationary term were vacated.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The police conducted a pat-down search of Defendant based on the dangerousness of the area and the flight of one of Defendant’s companions. As a result of the pat down, the police found marijuana, and Defendant was charged with misdemeanor possession of marijuana. Defendant moved to suppress the findings from the pat-down search as a violation of his Fourth Amendment rights. The trial court denied Defendant’s motion to suppress, concluding that the search was proper. The court of appeals affirmed. The Supreme Court of Arizona held that under the totality of the circumstances, the police did not have an individualized reasonable suspicion that Defendant was engaged in criminal activity and that Defendant was armed and dangerous sufficient to justify the pat-down search. The Court contrasted this case with Illinois v. Wardlow, 528 U.S. 119 (2000), where the U.S. Supreme Court sustained a frisk by police officers who were patrolling an area known for heavy narcotics trafficking where the defendant fled upon seeing the officers, holding that "ample suspicion that the defendant was engaged in criminal activity and was armed and dangerous arose not only from his presence in a high-crime area, but also 'his unprovoked flight upon noticing the police.'" By contrast, the question before the Arizona Supreme Court was whether reasonable suspicion justified frisking Defendant not because of anything he did or said but because someone else with whom he was conversing fled when police approached. Although the dangerousness of the area and the flight of the companion were relevant factors, the Court found that they were not enough to justify the search. Accordingly, the lower courts' holdings on Defendant's motion to suppress were reversed, and Defendant's conviction and probationary term were vacated.
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