State Supreme Court Data Tracker

Summary of Case Context & HoldingDefendants were serving life sentences for first degree murder and other crimes that they committed when they were juveniles. While Defendants were serving their sentences, the U.S. Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), which prohibited mandatory life sentences without parole for juvenile offenders convicted of homicide, and Montogomery v. Louisiana, 577 U.S. 190 (2016), which made Miller’s ruling apply retroactively. Defendants filed post-conviction relief petitions in 2016 to vacate their sentences under Miller, and the U.S. Supreme Court issued an order granting Defendants’ petition, vacating their sentences, and remanding for resentencing to the Arizona superior courts. While the resentencing proceedings were pending in superior court, the Supreme Court decided Jones v. Mississippi, 593 U.S. 98 (2021), which held that courts need only consider a juvenile offender’s “youth and attendant characteristics” when considering sentencing them to a non-mandatory sentence of life without parole. Based on this decision, the Arizona trial court vacated Defendants’ resentencings and dismissed the post-conviction relief petitions, agreeing with prosecutors, that the court had already considered the Defendants’ youth during the original sentencing and had not imposed a mandatory life sentence on either Defendant. Accordingly, the court held that resentencing was not constitutionally required. The court of appeals affirmed. Defendants then appealed under Ariz. Rev. Stat. Ann. § 13-4033, which allows defendants to appeal an order made after judgment affecting the substantial rights of the party. Defendants argued that vacating their resentencing impacts their substantial rights. The Arizona Supreme Court agreed and granted review. The Arizona Supreme Court reasoned that a resentencing is effectively a new case for sentencing purposes, and therefore, the constitutional right to appeal, from Article 2, Section 24 of the Arizona Constitution, applied to Defendants’ case, as it did to all criminal cases. Furthermore, the Supreme Court held that vacating resentencing and dismissing a post conviction relief petition unquestionably impacted the Defendants' substantial rights. The Court held that the lower courts improperly dismissed the resentencing mandated by the U.S. Supreme Court and remanded the case to the court of appeals to reinstate the resentencing proceedings and Defendants’ post-conviction relief petitions.

Summary of Case Context & HoldingThese consolidated appeals presented an issue of first impression for the New Jersey Supreme Court: whether police have the right to conduct a protective sweep of a home when an arrest is made outside the home and, if they do, what is the required justification for a warrantless entry and protective sweep. In State v. Radel, the court issued an order directing police to immediately retrieve firearms from Radel's home. Before conducting the search over two months later, police discovered Radel had two active arrest warrants, possessed firearms other than the one identified in the order, and resided at a different address than the one in the order. While surveilling the properties, the police heard a noise and saw someone enter and then saw Radel exit the home at one of the addresses. Police arrested him in front of the house and then conducted a protective sweep of the home. Police did not find anyone, but found in plain view imitation firearms, other weapons, drug paraphernalia and a gun safe. Police later obtained a warrant and found weapons, drugs, and cash. In State v. Terres, while attempting to execute an arrest for Tyler Fuller, police obtained information that Fuller may be staying with Defendant, Keith Terres. While in police custody, Terres told detectives that Fuller might be in a specific building in a trailer park. Police went to the building and saw two men inside. Neither was Fuller, but one man said Fuller was in a different trailer (that belonged to Terres) with another man and warned police to be careful because there were "two males back there." While two officers stayed with the men in the first trailer, the other two officers went to Terres's trailer where they observed Fuller and a woman. Fuller was detained by police and the woman indicated no one else was in the trailer. Police then conducted a sweep of the trailer, searching for the other man. While conducting the sweep, the officer looked into a partially covered hole in the floor that looked large enough for a person and saw guns. The next day, a warrant was issued and multiple weapons were seized from Terres's trailer. The Court held that when an arrest occurs outside a home, the police may not enter the dwelling or conduct a protective sweep in the absence of a reasonable and articulable suspicion that a person or persons are present inside and pose an imminent threat to the officers’ safety. This sensible balancing of the fundamental right to privacy in one’s home and the compelling interest in officer safety will depend on an objective assessment of the particular circumstances in each case, such as the manner of the arrest, the distance of the arrest from the home, the reasonableness of the officers’ suspicion that persons are in the dwelling and likely to launch an imminent attack, and any other relevant factors. A self-created exigency by the police cannot justify entry into the home or a protective sweep. Here, the court concluded that a protective sweep was not warranted in the Radel case but was constitutionally justified in the Terres case.

Summary of Case Context & HoldingIn this case a death row inmate's Racial Justice Act (RJA) motion was dismissed while the motion was pending before the court. The RJA permitted capital defendants to challenge their death sentences if they can prove that the decision, during their trials, to seek or impose the death penalty was racially motivated. However, the RJA was subsequently repealed. The case was dismissed because the RJA was repealed. The repeal included a provision to make the repeal apply retroactively. The Supreme Court reversed the dismissal of the Defendant's motion, holding that the repeal could not constitutionally be applied to the Defendant's pending RJA claims because the application of the repeal would violate the constitutional prohibition on ex post facto laws. An ex post facto law is one that has retroactive effect.

Summary of Case Context & HoldingThe Supreme Court affirmed an appellate court decision that held unconstitutional the continued seizure of Defendant after the conclusion of the apparent purpose of a traffic stop. In this case a state trooper conducted a thorough traffic stop that did not reveal criminal activity. The trooper had required the Defendant to stay seated in a vehicle, which is what constituted seizure of the Defendant. After the conclusion of the business of the traffic stop, the trooper asked to continue questioning the Defendant and eventually searched the Defendant's car. The Defendant argued on appeal that he was seized without consent or reasonable suspicion of criminal activity during which time the officer unlawfully seized items from the Defendant's car. The Supreme Court affirmed the decision and reasoned that the Defendant had not actually consented to the continuation of the stop because he was not informed that he was free to leave.

Summary of Case Context & HoldingAppellant was convicted of first-degree murder. Appellant argued that the trial court judge was biased against him due to the judge's statement, without prompting by the State, that he would consider revisiting a prior ruling on evidence concerning Appellant's past criminal conduct in the event that the Appellant decided to bring in new witnesses for testimony. The Appellant argued that the judge's statements effectively alerted the prosecution to raise the issue relating to the evidence of past criminal conduct again. The Supreme Court held that the judge's statement did not indicate the court's impartiality, but rather sought to preserve Appellant's right to a fair trial by allowing him to make an informed tactical decision regarding whether to offer the additional testimony. As a result, the Supreme Court affirmed.

Summary of Case Context & HoldingDefendant was charged with aggravated assault of a minor. Prior to trial, the State moved for an order directing the deposition of an expert witness who would be unavailable to testify at trial. The State served a notice of the deposition, specifically inviting Defendant and his counsel to attend. Defendant’s counsel attended, but Defendant did not. At the start of Defendant’s trial, the State announced its intention to place a videotape and the transcript of the deposition into evidence. Neither Defendant nor his counsel objected. Defendant was convicted of aggravated assault and appealed, arguing that his absence from the deposition of a State witness violated his right to be present at all critical stages of the proceedings. The Court held that such right of presence claims are not excepted from the general rule that a constitutional violation must first be presented to the trial court. In the absence of a timely objection in the trial court, the defendant must obtain review of a right of presence claim under one of the established methods, such as the plain error doctrine. To establish the need for plain error review, a defendant must: (1) show the claimed error implicates a fundamental right; and (2) firmly convince the court that failure to review the error would result in a manifest miscarriage of justice, leave unsettled the question of the fundamental fairness of the trial or proceedings, or compromise the integrity of the judicial process. While the right of presence is a fundamental right–passing prong one of the plain error review test–the Court determined that plain error review was not warranted, because Defendant had not explained how he could have meaningfully contributed to his counsel's cross-examination of the deposed witness.

Summary of Case Context & HoldingDefendant Rick had a homosexual relationship with another man, D.B., in which they mutually agreed to not use condoms despite Rick's prior disclosure that he was HIV positive. D.B. was subsequently diagnosed with HIV and after the relationship ended, sought prosecution of Rick under Minnesota’s “knowing transfer of a communicable disease” statute. The state charged Rick with attempted first-degree assault with great bodily harm, under the subdivision of the statute governing sexual penetration, which contains an exception if there has been verbal disclosure, as well as under the subdivision governing the medical transfer of blood, sperm, organs, or tissue, which does not contain the verbal disclosure exception. The jury found D.B guilty under the medical transfer provision. The appeals court reversed the conviction and the Minnesota Supreme Court affirmed, holding that based on canons of statutory interpretation and legislative history, the State's interpretation of the medical transfer provision was unreasonable and was not intended to criminalize the transmission of sperm through sexual conduct.

Summary of Case Context & HoldingDefendant who carried the human immunodeficiency virus (HIV) was convicted in a jury trial in the district court of attempted first-degree assault by transferring a communicable disease in the course of having consensual sex. The Minnesota communicable-disease statute, codified at Minn. Stat. § 609.2241, makes it a crime for a person who knowingly harbors an infectious agent “to engage in behavior that has been demonstrated epidemiologically to be a mode of direct transmission” of the infectious agent, if the crime involved the “transfer of blood, sperm, organs, or tissue.” The court of appeals reversed the district court's decision on the ground that the statute is ambiguous because it is subject to more than one reasonable interpretation. The Supreme Court affirmed, holding that: (1) the Minnesota communicable-disease statute was ambiguous for purposes of determining whether Defendant could be convicted of attempted first-degree assault under the statute by transferring HIV to a partner in the course of consensual sexual relations; and (2) subsection criminalized transmission of the disease through the donation or sale of blood, sperm, organs, or tissue for medical purposes, and not the transmission through sexual conduct.

Summary of Case Context & HoldingDefendant was charged with reckless injury for shooting someone at a drug deal gone wrong. Defendant moved to suppress the victim’s out of court identification, made using a Facebook photo rather than a photograph array. The Supreme Court held that the victim’s identification was reliable and therefore admissible. Even if the identification was partially unreliable due to not being based on an array, that question was properly left to the jury, and it was correct for the judge to admit the identification into evidence.

Summary of Case Context & HoldingThe appellate court remanded a death penalty sentence for resentencing specifically calling the matter of allocution to the trial judge's attention. However, in its resentencing opinion, the trial judge did not properly discuss or consider the Defendant's allocution in reimposing the sentence, which allocution contained information relevant to mitigation. The Supreme Court held that while a trial court may permissibly deny a defendant's motion to fully present mitigation evidence at trial, failure to properly consider allocution at sentencing may violate a defendant's Eighth Amendment rights. Accordingly, such vacated the Defendant's death sentence and remanded the case for resentencing. The Defendant also argued that she was not competent to stand trial during her resentencing, but the Supreme Court rejected this claim because the Defendant failed to provide by a preponderance of the evidence that she was incompetent; and the Supreme Court rejected her claim that she had not been competent during her original mitigation hearing, finding that this claim was barred by res judicata because the Defendant could have raised the issue in the initial appeal.

Summary of Case Context & HoldingThe New Jersey Supreme Court considered the newly enacted Criminal Justice Reform Act to address the type and scope of discovery the State must provide when it seeks to detain a defendant prior to trial. Police arrested Defendant Robinson for killing a victim. According to the affidavit, two eyewitnesses saw the shooting. One identified Defendant from a six-person photo array while the other identified a photo of Defendant. The Preliminary Law Enforcement Incident Report (PLEIR) added that a surveillance camera recorded the incident. The pending complaint charged Defendant with first-degree murder and weapons offenses. The Public Safety Assessment (PSA) recommended that Defendant not be released. At the pretrial detention hearing, the State relied on the hearsay statements in the affidavit of probable cause (which referred to the two eyewitnesses); the presumption of detention under N.J.S.A.2A:162-19(b)(1) (based on the murder charge); Defendant's criminal history and record of court appearances; and the release recommendation in the PSA. The trial court directed the State to disclose the two witness statements, the photos used in the identification process, the surveillance video, and any incident report that the police prepared. The State appealed. The Appellate Division affirmed the trial court. The Supreme Court found that Rule 3:4-2(c)(1)(B), on which the lower courts relied, required disclosure of the reports and the photos but not the video. The Supreme Court clarified the Rule to balance a defendant's liberty interest and the State's ability to seek the detention of high-risk defendants before trial.

Summary of Case Context & HoldingThe Arizona Supreme Court upheld the conviction and death sentence of Dwandarrius Jamar Robinson for the brutal murders of his pregnant girlfriend, Shaniqua Hall, and their unborn child. Robinson bound, gagged, and set fire to Hall in their apartment, resulting in both deaths. The prosecution presented strong forensic and circumstantial evidence, including duct tape, lighter fluid, and a handcuff key found in Robinson’s possession. Although Robinson appealed, the Court found no reversible error in the trial or sentencing phases. The Court affirmed that the evidence supported the jury’s findings and upheld the imposition of the death penalty.

Summary of Case Context & HoldingIn this case a death row inmate moved for relief pursuant to the North Carolina Racial Justice Act (RJA) and obtained relief in the form of a life sentence without parole. The RJA permitted capital defendants to challenge their death sentences if they can prove that the decision, during their trials, to seek or impose the death penalty was racially motivated. However, the RJA was subsequently repealed. The trial court retroactively applied the RJA's appeal to the inmate. The Supreme Court, in a divided decision, held that the State Constitution's prohibition on double jeopardy prevented the retroactive application of the RJA appeal after the inmate's sentence was reduced to life without parole. This was because the retroactive application of the RJA violated the State Constitution's protections against double jeopardy. Under this protection, acquittals end original jeopardy of a case and are thus final and unreviewable. Because the mitigation of the Defendant's sentence is an acquittal of the death penalty, the Supreme Court ruled that the relief provided to Defendant could not be challenged following the RJA's repeal.

Summary of Case Context & HoldingDefendant was convicted of first-degree murder and sentenced to death. The record contained evidence that Defendant had "intellectual limitations, mental health diagnoses, and emotional turmoil." However, at the Defendant's capital sentencing hearing, the trial court did not submit instruction to the jury on a possible mitigating circumstance. Specifically, the trial court did not submit to the jury that a defendant's sentence could be reduced when the defendant lacked the capacity to appreciate the criminality of their conduct or when the defendant's ability to conform their conduct to the law was impaired. The Supreme Court remanded the case for a new capital sentencing hearing, finding that the trial court, acting voluntarily, erred in failing to submit the mitigating circumstance to the jury. The Supreme Court reached this conclusion because the Defendant was sentenced to death so the Supreme Court could not conclude that the failure to submit the mitigating circumstance to the jury was harmless beyond a reasonable doubt.

Summary of Case Context & HoldingFollowing convictions on guilty pleas entered in the circuit court for homicide by intoxicated use of motor vehicle and driving without a license resulting in death, Defendant filed a motion for post-conviction relief seeking vacatur of convictions, or in alternative, vacatur of the sentence and a new sentencing hearing. The Defendant claimed that the circuit court mentioned his status as an illegal immigrant several times. The Supreme Court held that the trial court did not improperly consider Defendant's nationality as an aggravating factor in sentencing. Instead, the trial court only used the Defendant's "willingness to violate this country's immigration laws" as a reflection of the Defendant's character, which was proper.

Summary of Case Context & HoldingThe State of Texas sued the San Antonio Independent School District (ISD) in response to the District's requirement that its employees receive the Covid-19 vaccine by October 15, 2021. The district court denied the State's request for a temporary injunction, and the court of appeals affirmed. The State petitioned for review. In June 2023, the Court held in Abbott v. Harris, 672 S.W.3d 1, 21 (Tex. 2023) that GA-38a gubernatorial order prohibiting local mask requirements—was "a valid exercise of the Governor's authority under the Disaster Act." On September 1, 2023, Senate Bill 29 went into effect which provides, in relevant part, that "a governmental entity," including a school district, "may not implement, order, or otherwise impose a mandate requiring a person to be vaccinated against COVID-19." Also in June 2023, both GA-38 and GA-39 expired. GA-39 was also a gubernatorial order which similarly prohibited governmental entities from compelling individuals to receive the Covid-19 vaccine. Accordingly, the State contended that the appeal is moot because the State sought a temporary injunction to enforce GA-39, which had lapsed, and because Senate Bill 29 statutorily prohibited any vaccine mandate imposed by the ISD. While the ISD does not contend that it retained authority to impose vaccine requirements in spite of Senate Bill 29, it argued that a live controversy remained because the parties disagreed about the scope of the Governor's authority during future disasters. The Court agreed with the State that the appeal was moot as there was no longer a live controversy following the passage of SB 29 and the expiration of GA-39. Thus, the Court vacated the opinion of the court of appeals and dismissed the appeal.

Summary of Case Context & HoldingAfter being convicted of repeated sexual assault of child, incest, and child enticement for conduct occurring when Defendant was 14 to 18 years old, Defendant brought a post-conviction motion, alleging that his trial counsel was ineffective for failing to bring pre-trial motion to dismiss charges for repeated sexual assault of child for conduct occurring when Defendant was nine to 12 years old. The Supreme Court held that the circuit Court possessed statutory competency to hear criminal charges against adult Defendant for conduct he committed before his 10th birthday. Wisconsin courts have uniformly held that statutory competency is determined by the age of the accused at the time charges are filed, not the age of the accused at the time the underlying conduct occurred. Specifically, the Supreme Court reasoned in part that if the state could not prosecute adults for conduct committed as juveniles, then the state would be subject to a time limitation (the time between commission of the act and the juvenile's 17th birthday).

Summary of Case Context & HoldingDefendant was charged with improper possession of a firearm after he was frisked by police. Police approached Defendant at night and, when addressing him, Defendant approached police voluntarily and conversed with them. Upon Defendant's admission he was carrying a firearm, police instructed Defendant to put his hands on his head. Defendant informed the police that he had a felony conviction and he was arrested. Defendant sought suppression of the firearm but the trial court denied the motion and the court of appeals affirmed on the grounds of officer safety. On appeal to the Supreme Court, Defendant's conviction was reversed. The Court, looking to Terry v. Ohio, 392 U.S. 1 (1968), recognized that stop and frisk required both that the suspect be perceived as armed and presently dangerous and that criminal activity were a afoot. The Court rejected arguments that being armed alone, along with concerns for officer safety, were enough for Defendant to be searched. The Court rejected the State's argument that because the stop began as a voluntary interaction, the search was proper, noting that the voluntariness of the interaction ceased as soon as the officer commanded Defendant to put his hands on his head. Thus, the Court determined the search to be violative of the Fourth Amendment and reversed Defendant's conviction and sentence.

Summary of Case Context & HoldingDefendant intentionally set a fire inside of a truck and was convicted of arson of an occupied structure. The court of appeals, on its own motion, ordered supplemental briefing on the arson conviction based on the prosecutor’s statement that Defendant’s “presence alone” made the truck an occupied structure. The court of appeals held that there was no evidence of anyone besides the Defendant in or near the truck when the fire started, and that Defendant’s presence alone was sufficient to satisfy the occupancy requirement. The Supreme Court addressed an issue of first impression: whether an arsonist’s lone presence at the site of the crime is enough for it to be considered an “occupied structure” under Ariz. Rev. Stat. § 13-1704 because the arsonist qualifies as a “human being” under the definition of occupied structure in Ariz. Rev. Stat. § 13-1701(2). The Court held that the definition of occupied structure unambiguously excludes the arsonist because an alternative interpretation would render the tiered arson statutory scheme nearly superfluous. Arson of an occupied structure is the most severe arson offense. Based on the context and plain meaning of the statute, the Court explained that while the arsonist literally meets the definition of a “human being,” the definition must be considered in context. The context includes that the arsonist is referred to as a “person” who damages the occupied structure (not “human being”), which signals the distinction between the arsonists and the object of the offense. Further, the context of the broader statutory scheme creates three tiers of arson, including one where the structure is not occupied. If the arsonist counted as a “human being” for purposes of a structure being occupied, this statutory scheme would not make sense. The Court vacated the opinion of the court of appeals, vacated the conviction and sentence, and remanded the case to the trial court.

Summary of Case Context & HoldingDefendant pled guilty in the circuit court for possession with intent to deliver marijuana. Defendant's postconviction motion to withdraw the plea, on ineffective assistance of counsel grounds, was denied. The Supreme Court held that the attorney was not required to tell Defendant that his conviction would absolutely result in deportation, abrogating State v. Mendez, 847 N.W.2d 895 (Wis. Ct. App. 2014). The Supreme Court denied Defendant's motion because, while the attorney did not say the guilty plea would absolutely result in deportation, the attorney did say that the guilty plea carried a "strong chance" of deportation. In fact, the Defendant's deportation was not an absolute certainty due to prosecutorial discretion.

Summary of Case Context & HoldingDefendant gave pre trial notice of her intent to offer the affirmative defense of duress. During trial, the State sought and was allowed to impeach Defendant before she took the stand. On appeal, the court found that the trial court did not err in allowing the impeachment testimony preemptively because the Defendant gave notice of her intent to assert the affirmative defense. The Supreme Court reversed the court of appeals, finding that a defendant does not forfeit their Fifth Amendment right to silence by giving pretrial notice of intent to raise an affirmative defense of duress. The Supreme Court reasoned that the pre-trial notice did not compel the Defendant to testify, nor clearly show that she intended to testify. As a result, the Supreme Court held that the State cannot preemptively impeach a defendant during its case-in-chief.

Summary of Case Context & HoldingThis case concerns the right to counsel. The Defendant was charged and convicted of offenses related to failure to maintain a valid license at trial. The record contained a waiver of counsel form that was signed by the trial judge but not by the Defendant. The judge noted that the Defendant refused to sign the form and was unresponsive to the judge's inquiries. When the Defendant appealed to the superior court, he was tried and convicted without counsel. During the superior court trial, the Defendant asked for counsel that was not paid for by the State and the superior court determined that Defendant had waived his right to counsel. On appeal, the court of appeals found that the trial court had not ensured Defendant's waiver of counsel was knowing, intelligent, and voluntary. This standard requires that a defendant be clearly advised of the right to counsel, the defendant understands the consequences of proceeding pro se, and the defendant understands what is happening in the proceeding including the range of punishments. The Supreme Court affirmed the finding of the court of appeals. The Supreme Court reasoned that based on review of the transcript from the trial, Defendant's waiver was insufficient to meet the requirements of the standard and noted that the judge at trial deemed the right waived within 20 minutes of the beginning of the trial.

Summary of Case Context & HoldingPolice officers smelled marijuana coming from a warehouse, so they obtained a warrant to search a unit in the warehouse. The officers seized marijuana growing equipment and marijuana in the warehouse. The trial court denied Defendant’s motion to suppress, concluding that the passage of the Arizona Medical Marijuana Act (AMMA), which made marijuana legal for medicinal use, did not impact the determination that the odor of marijuana suffices to establish probable cause for issuance of a search warrant. The court of appeals reversed, holding that after the adoption of AMMA, the scent of marijuana, alone, is insufficient evidence of criminal activity to supply probable cause. The Supreme Court vacated the court of appeals’ opinion and affirmed the trial court’s ruling denying the motion to suppress, holding that (1) as matter of first impression, odor or sight of marijuana suffices to establish probable cause to search unless other facts would cause a reasonable person to believe the marijuana use or possession is authorized by the Arizona Medical Marijuana Act; and (2) probable cause supported issuance of warrant to search storage unit occupied by Defendant.

Summary of Case Context & HoldingReproductive healthcare clinics, physicians, and non-profit organizations challenged the constitutionality of Georgia’s 2019 law, Living Infants Fairness and Equality Act (LIFE Act), which banned abortions after a detectable human heartbeat in a fetus. The case initially went through Federal Court, where, in 2020, the Federal District Court ruled that the LIFE Act was unconstitutional under existing U.S. Supreme Court precedent. That decision was overturned by the U.S. Court of Appeals for the Eleventh Circuit following the U.S. Supreme Court’s 2022 decision in Dobbs v. Jackson’s Women’s Health Organization, 597 U.S. 215 (2022). Appellees then filed a new lawsuit in state court arguing that the LIFE Act was void ab initio (null from the beginning) because it was unconstitutional when enacted. The state trial court agreed that the LIFE Act violated the controlling U.S. Supreme Court precedent set in Roe v. Wade, 410 U.S. 113 (1973) and Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833 (1992) at the time it was enacted, rendering the act void ab initio even though the precedent had been overturned. The Supreme Court reversed, holding that the LIFE Act was not void even though it violated the U.S. Constitution under controlling precedent at the time it was enacted because precedent that has since been overruled cannot establish that a law was unconstitutional when enacted. The Supreme Court reasoned that the trial court’s conclusion was based on an incorrect premise that the Dobbs decision changed the meaning of the Constitution itself. Rather, the Supreme Court reasoned that the U.S. Supreme Court only has the power to interpret the original meaning of the Constitution. According to the Supreme Court, because the U.S. Constitution had not been amended since the LIFE Act was enacted and the only change was the U.S. Supreme Court’s interpretation, the law complies with the U.S. Constitution as interpreted today and cannot be void ab initio.

Summary of Case Context & HoldingAt the age of thirteen, Petitioner Conrad Slocumb kidnapped and sexually assaulted a teacher before shooting her in the face and head five times and leaving her for dead. Three years later, following his guilty plea for the first set of crimes, he escaped from custody and raped and robbed another woman in a brutal manner before being apprehended. For these two sets of crimes, Slocumb received an aggregate 130-year sentence with the individual sentences running consecutively. Slocumb argued that his 130-year sentence for multiple offenses violates the Eighth Amendment under principles from Graham v. Florida, 560 U.S. 48 (2010) and Miller v. Alabama, 567 U.S. 460 (2012). In Graham, the Supreme Court held that the Eighth Amendment prohibited “the imposition of a life without parole sentence on a juvenile offender who did not commit homicide,” while in Miller, the Supreme Court held that the Eighth Amendment forbade states from imposing on juveniles mandatory sentences of life without the possibility of parole for homicide offenses. Although Slocumb argued that his case presented a reasonable potential extension of those cases, the South Carolina Supreme Court held that only the U.S. Supreme Court has the authority to expand federal constitutional protections. Bound by precedent, the Court denied Slocumb relief, noting that any extension of the Eighth Amendment must come from the Supreme Court.

Summary of Case Context & HoldingOfficer Taranto was conducting surveillance in front of a condo complex in an area known for narcotics transactions and other criminal activity. Based on information from a confidential informant (CI) received a month prior, Officer Taranto identified a car parked in the complex that had been involved in prior drug deals and was supposedly used by a drug dealer known as "Killer" and began to watch it. After 30 minutes, Defendant, a woman (the driver), and a child entered the car and drove to a residence where Officer Taranto saw activity consistent with a drug transaction. Officer Sutter, who knew multiple drug users lived at the residence and was informed 2 months earlier by a "concerned citizen" that drug activity occurred there, had also followed the car to the residence. Based on their observations, the officers suspected that Defendant engaged in drug deals at the residence. The observations, the officers' investigations combined with the CI information led the officers to believe they had reasonable and articulable suspicion to conduct an investigative stop. The police searched Defendant during the stop and did not find any incriminating evidence. The police decided to call for a dog to perform an exterior sniff of the car. Twenty-three minutes after initiating the stop, an officer arrived with the dog whose positive hit on the car established probable cause. Police searched the vehicle and found drugs, drug paraphernalia, weapons, and ammunition. The trial court suppressed the evidence seized from the search. The issue before the New Jersey Supreme Court was whether the automobile exception, which requires that circumstances giving rise to probable cause be "unforeseeable and spontaneous" in addition to the inherent mobility of the automobile, permitted the warrantless search of Defendant's car. The Court held that the circumstances giving rise to probable cause in this case were not “unforeseeable and spontaneous," the standard set by State v. Whitt, 126 A.3d 850 (N.J. 2015). Those circumstances included investigating previous information from the CI and a concerned citizen, the identification of the vehicle by the CI as one involved in prior drug deals and used by a drug dealer, and narcotics trafficking in the area; lengthy surveillance of defendant and the vehicle; reasonable and articulable suspicion that Defendant had engaged in a drug deal; and a positive canine sniff of the vehicle. The Court therefore affirmed the order suppressing the physical evidence seized from the vehicle.

Summary of Case Context & HoldingJon Smart and a co-defendant were in custody at a juvenile justice detention facility when they murdered a citizen volunteer who had allowed the boys to work on his farm as part of their rehabilitation. Afterwards, the duo stole the volunteer’s truck and went on a violent crime spree in the area, eventually leading to a high-speed chase with officers. Smart was 16 years old at the time. After pleading guilty, the plea court sentenced him to life in prison for the murder. Smart later sought resentencing pursuant to Aiken v. Byars, 765 S.E.2d 572 (S.C. 2014) where the U.S. Supreme Court held that mandatory life without parole for juveniles violates the Eighth Amendment and requires individualized resentencing hearings that consider the mitigating characteristics of youth. The circuit court again sentenced Smart to life without parole. Smart appealed, arguing that the resentencing court improperly placed the burden of proof or persuasion on him and should have placed the burden on the State. The Supreme Court disagreed, and upheld the circuit court’s resentencing. The Supreme Court clarified that in an Aiken resentencing hearing, there is no burden of proof or persuasion on either party, and instead, the resentencing court must consider all evidence and arguments presented at the resentencing hearing de novo, reaching an outcome without any deference or thought to the sentence previously imposed. Although the Supreme Court acknowledged there was language in the resentencing court’s oral ruling that might be interpreted to suggest that the court placed an improper burden on Smart, this was simply a misstatement. The Supreme Court found that the resentencing court followed the proper procedure under Aiken by methodically considering all evidence presented and treating the proceeding as a de novo resentencing hearing, with no burden of proof or persuasion on Smart.

Summary of Case Context & HoldingDetectives stopped the Defendant's vehicle for a purported window tint violation after seeing a dark tint on his rear windshield, through which they could nevertheless see the Defendant making a shoving motion as though hiding something. After a search pursuant to the stop, they found a firearm in the car. The Defendant moved to suppress the evidence, arguing that the detectives did not have a reasonable and articulable suspicion that the window tint violated N.J.S.A. 39:3-74. The trial court denied the motion, holding that the stop was instead supported by an adjacent statute N.J.S.A. 39:3-75, which governs requirements for automotive safety glass. The issue presented to the New Jersey Supreme Court was whether N.J.S.A. 39:3-75 justified the stop for a window tint violation. The Supreme Court held that: (1) the officers' seeing a dark tint on the rear windshield did not justify the traffic stop for a tinted windows violation; (2) the statute governing automotive safety glass did not apply to window tint violations; (3) a community caretaking function did not authorize the vehicle stop; and (4) the statute prohibiting operation of vehicle with non-transparent material on front windshield or front side windows was not unconstitutionally vague. The Court reasoned that N.J.S.A. 39:3-75 did not apply to window tint violations. The Court also reasoned that, consistent with the plain language of N.J.S.A. 39:3-74, reasonable and articulable suspicion of a tinted windows violation arises only when a vehicle’s front windshield or front side windows are so darkly tinted that police cannot clearly see people or articles within the car. A statute is unconstitutionally vague, in violation of due process, if persons of common intelligence must necessarily guess at its meaning and differ as to its application. The Court reasoned that the term “non-transparent” in the statute is not impermissibly vague, as reasonable suspicion of a tinted windows violation arises when a vehicle’s front windshield or front side windows are so darkly tinted that police cannot clearly see people or articles within the car. Here, the detectives were able to see the person and the actions he was taking within the car, so reasonable suspicion did not arise. Furthermore, community caretaking did not justify the stop because the police knew there was no obstruction of the driver's vision or a hazardous condition of the vehicle that deviated from the norm. Therefore, the Supreme Court held that the traffic stop was not justified.

Summary of Case Context & HoldingDefendant was arrested for the death of Defendant's girlfriend and child abuse. At trial, the jury found the Defendant guilty of first-degree murder and intentional child abuse, with two aggravators, sentencing Defendant to death. Defendant, on appeal, argued that the trial court made several prejudicial errors that affected the outcome of his trial. The Supreme Court affirmed Defendant's convictions and sentences for first-degree murder and child abuse, holding that no prejudicial error occurred during the trial proceedings. Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to suppress, because even though the police did not have a warrant for his cell site location information, courts have consistently upheld that the good faith exception applies to CSLI orders; (2) the trial court did not violate the Due Process Clause by admitting a pretrial identification of Defendant; (3) the trial court did not err in denying Defendant's Batson challenges (prohibiting an individual from serving on a jury based on race violates the Equal Protection Clause) to the State's peremptory strikes of two jurors; (4) the trial court did not err by admitting a video demonstrating the location and movement of Defendant's and the victim's cellphones on the day of the murder; (5) the trial court did not err by restricting Defendant's cross-examination of the State's former case agent; (6) the trial court did not commit fundamental error by failing to reinstruct the jury at the close of the aggravation stage; (7) substantial evidence supported the jury's finding that Defendant killed the victim for pecuniary gain; (8) the jury was properly instructed; (9) the State did not engage in prosecutorial error; and (10) the jury did not abuse its discretion in sentencing Defendant to death.

Summary of Case Context & HoldingDefendant was accused of sexual activities with an underage student while working as an In-School Suspension and P.E. teacher. Defendant argued for the case to be dismissed because he was not classified as a "teacher," and therefore could not be charged with engaging in sexual activity with a student. The Supreme Court concluded that the statute was written to protect students from sexual encounters with adults, so titles such as "teacher" should be interpreted functionally. The Supreme Court stated that the facts of the case justify categorizing the defendant as a teacher, noting that the decision was not made by a technical decision regarding title. Defendant worked at the school full time, operated as a substitute teacher, was an employee of the school district, and was teaching P.E. as preparation for becoming a full time teacher.

Summary of Case Context & HoldingAppellant was convicted of two counts of first-degree premeditated murder related to the shooting deaths of two people. Appellant had been the victim of several burglaries. On Thanksgiving Day in 2012, Appellant moved his car out of his driveway (evidently to make it appear that he was not home), and then went back to his house and waited, armed, in his basement. After some time, an intruder entered the home and came down the basement stairs, at which point Appellant shot the intruder. Appellant shot the intruder several additional times to ensure the intruder was dead. Appellant waited for about 30 minutes, at which point an accomplice entered the home and descended the basement stairs. Appellant shot and killed this person as well, shooting six times total. Appellant waited until the following day, then called his friend and neighbor, who, in turn, called the police. Appellant was arrested when the police arrived and heard his story. The Appellant appealed the decision, alleging a number of things, including that the Appellant suffered substantial prejudice when the State attempted to impeach Appellant's friend and neighbor. The State incessantly questioned the neighbor regarding whether Appellant had specifically asked for a defense lawyer, not just any lawyer, in the phone call that occurred the day following the murders. Appellant argued this line of questioning tarnished the neighbor's credibility. Although the Supreme Court of Minnesota found the prosecutor's persistent line of question troubling, the Court ruled that it did not substantially influence the grand jury's decision to indict (the standard needed to find prosecutorial misconduct) because the evidence was otherwise overwhelming.

Summary of Case Context & HoldingThis case consolidated the appeals of three Defendants who were convicted of several criminal offenses (i.e., murder, armed robbery, arson) as teenagers. All three were sentenced to concurrent and consecutive prison sentences that totaled over 100 years. Defendants argued these sentences violated the Eighth Amendment’s prohibition against “cruel and unusual punishment.” The Supreme Court considered whether consecutive sentences imposed for separate crimes committed by juveniles, when the cumulative sentences exceed a juvenile's life expectancy, violated the Eighth Amendment. Prior United States Supreme Court precedent (Graham v. Florida, 560 U.S. 48 (2010); Miller v. Alabama, 567 U.S. 460 (2012); Montgomery v. Louisiana, 577 U.S. 190 (2016)) held that sentencing juvenile defendants to a life sentence without the possibility of parole for a single crime usually violated the Eighth Amendment. However, the Arizona Supreme Court concluded that these Supreme Court precedents were not applicable in this case because Graham, Miller, and Montogomery dealt with sentencing juveniles to life without the possibility of parole for one crime, and here, Defendants’ sentences were not parole-ineligible life sentences, but rather, consecutive sentences arising from multiple convictions. The Court concluded that a categorical ban on such de facto life sentences would violate the Arizona Constitution, specifically the Victims’ Bill of Rights (VBR) because the VBR requires a sentencing court to consider victims individually. The Court reasoned that prohibiting de facto life sentences for juveniles would effectively deny victims justice because it would artificially cap a juvenile defendant’s sentence. Furthermore, the Court explained that such categorical sentencing bans are meant for legislators to decide and not the courts. Therefore, the Court concluded that aggregated consecutive sentences for separate crimes that exceed a juvenile's life expectancy did not violate the Eighth Amendment of the U.S. Constitution.

Summary of Case Context & HoldingDefendant was on trial for 11 counts of aggravated murder and the jury recommended death sentences for all 11 murders, which the trial court accepted. On appeal, the Defendant argued that his fundamental Sixth Amendment right to a public trial was denied when the trial court closed the courtroom during an evidentiary hearing regarding the suppression of certain incriminating evidence, and when it closed the courtroom during jury voir dire. The Supreme Court ruled that although the trial court had failed to follow the necessary procedures in making the proceedings non-public, the hearing did not mandate a new evidentiary hearing because a new hearing would not have resulted in a material change in the positions of the parties, even where there is prejudice from the closures.

Summary of Case Context & HoldingDefendant was arrested for DUI. He had a prior conviction for DUI and was considered a repeat offender. The Justice of the Peace ordered Defendant to participate in Montana’s 24/7 Sobriety Program, a program enacted by the legislature in 2011 to give courts and prosecutors more options for sentencing repeat DUI offenders. The 24/7 Sobriety Program authorized assessment of fees related to the program, which conducted regular breath tests and counseling. After Defendant missed three mandatory tests under the 24/7 Sobriety Program, he was charged with three counts of contempt. In response, Defendant moved to dismiss all three of the charges, arguing that the legislation which created the 24/7 Sobriety Program was unconstitutional. The district court held that the 24/7 Sobriety Program constituted an improper delegation of legislative authority because it failed to provide objective criteria for determining the amount of fees that should be charged to repeat offenders. The district court also determined that the 24/7 Sobriety Program, as a condition of bond, constituted pre-trial punishment that violated the due process rights of criminal defendants. The State appealed. The Court reversed the district court’s determination that the 24/7 Sobriety Program was unconstitutional. The Court held that the legislature may delegate its legislative powers to an administrative body so long as it sets forth a policy, rule, or standard for guidance and does not vest them with an arbitrary and uncontrolled discretion. The Defendant argued that the 24/7 Sobriety Program gave the court “unfettered discretion when implementing fees.” The Court disagreed concluding that there was ample guidelines and limiting instructions because the “Legislature limited the fees to reasonable amounts necessary to pay for the administration of the program.”

Summary of Case Context & HoldingThe Court affirmed a death sentence on direct appeal in 1997. Later, a federal court denied Defendant’s petition for habeas corpus. The Ninth Circuit reversed in part and remanded to the district court, concluding the Supreme Court of Arizona applied an unconstitutional “causal nexus” test and, therefore, failed to properly consider evidence of Defendant’s longstanding alcohol and substance abuse as mitigation evidence. The State filed a motion asking the Supreme Court of Arizona to conduct a new independent review. On review, the Court held that mitigation evidence was insufficient to warrant leniency and affirmed the death sentence. Defendant was found guilty of first-degree murder (premediated and felony murder), sexual assault, and kidnapping. During the aggravation-mitigation hearing, the trial court found one aggravating factor (murder in an especially cruel manner), which outweighed mitigation evidence of emotional immaturity, no prior felonies, and capability for rehabilitation. In its review, the Court considered these factors as well as Defendant’s history of drug and alcohol abuse. Non-statutory mitigating circumstances must be established by a preponderance of the evidence. The Court found Defendant successfully established his history of substance abuse, but failed to establish a sufficient connection between the substance abuse and circumstances of the murder to entitle the mitigation evidence significant weight because the Doctor that testified on his behalf qualified his conclusions in favor of Defendant, and other evidence indicated Defendant did not lack the capacity to appreciate the wrongfulness of his conduct. The Court also independently reviewed evidence of Defendant’s difficult upbringing, including his father’s absence and mother’s non-nurturing behavior, that impacted his social skills and gave little weight to such evidence because expert testimony confirmed Defendant does not currently show signs of an acute emotional disorder and did not suffer a deficit that would prevent him from knowing right or wrong. The Court also reviewed Defendant’s evidence of remorse, lack of adult convictions, future dangerousness, model prisoner behavior, and other non-statutory circumstances, and also entitled each little weight. The Court concluded that, considering all mitigation evidence without regard to any causal connection, the mitigation evidence is insufficient to warrant leniency especially in light of the cruel aggravating circumstances. Defendant’s death sentence was affirmed.

Summary of Case Context & HoldingMinnesota State Patrol responded to a 911 call regarding a vehicle crash. Based upon an investigation at the scene, officers determined that the accident resulted in one fatality, that the alleged driver, Appellant, was seriously injured, and that alcohol may have been a factor in the accident. While in the hospital, Appellant admitted to police having been the driver of the vehicle and that he had been drinking. The officers observed that he smelled strongly of alcohol, and that he had sustained serious injuries that required treatment and transport by helicopter. On that basis, an officer obtained a warrantless blood draw from Appellant and later testing of that blood revealed an alcohol concentration of 0.20. Appellant was charged with three counts of criminal vehicular operation resulting in death, two counts of fourth-degree driving while impaired, reckless driving, and careless driving arising out of a single-vehicle rollover crash. Appellant moved to suppress the alcohol concentration test results from a blood draw taken after the accident on the grounds that his blood was drawn without a warrant and without his consent. The district court granted the motion to suppress concluding, in part, that the State failed to satisfy the exigent circumstances exception as applied in Missouri v. McNeely, 569 U.S. 141 (2013). In McNeely, the court held that the natural and gradual dissipation of alcohol in a defendant's bloodstream itself does not constitute exigency in every drunk driving case to justify a warrantless blood draw, and rather, the inquiry is whether, under all facts available at the time of the search, the conclusion that the officer was faced with an emergency, in which delay to obtain a warrant would significantly undermine the efficacy of the search. The court of appeals reversed, concluding that the State established exigent circumstances that justified the warrantless search. The Supreme Court of Minnesota agreed that the State established that exigent circumstances justified the warrantless blood draw in this case, on the basis that (i) the smell of alcohol, and (ii) it would take enough time to transport Appellant to the hospital for a blood test that alcohol levels would be ineffective if it was not taken immediately.

Summary of Case Context & HoldingA police officer arrested, coerced a confession from, charged, and imprisoned an innocent minor for a felony crime that the officer knew the minor did not commit as revenge against the minor's mother. The officer argued that he cannot be prosecuted for intimidation based on the actions he took while conducting an the interrogation of the minor. The Supreme Court disagreed holding that a police officer may be prosecuted for the offense of intimidation and noting and reasoning that while a police officer may use wide-range of interrogation tactics, there is no authority for use of physical force, unlawful threats of harm, or a materially false or fraudulent writing with malice, bad faith, wantonness, or recklessness as part of a legitimate interrogation. The Supreme Court also considered whether the appellate court properly found that the jury instructions for one of the Defendant's charges constituted plain error, thereby warranting overturning the officer's conviction on this charge. The Supreme Court held that the trial court's erroneous jury instructions did not rise to the level of plain error because the appellate court did not consider the entire record as a whole to determine whether a manifest miscarriage of justice occurred as a result of the error in the instructions.

Summary of Case Context & HoldingDefendant was convicted of resisting a law enforcement officer and pointing a firearm at an officer. At trial, the jury was not given a self-defense instruction, seemingly because the trial court disbelieved Defendant's testimony regarding the event. The Supreme Court held that there was sufficient evidence for the jury to conclude that the Defendant reasonably believed the two officers were not officials based on his testimony and that it should be left to the jury, not the trial judge, to determine the Defendant's credibility as a witness. Accordingly, the Supreme Court determined that the Defendant was entitled to a jury instruction on self-defense.

Summary of Case Context & HoldingAfter a friend refused to lend him more money, Defendant entered the friend’s girlfriend’s home and killed the friend, the girlfriend, and her four children by asphyxiation and gunshot. The State indicted Defendant nine years later, by which time he was already serving a life sentence for an unrelated murder. The State alleged four aggravating factors, and the jury sentenced Defendant to death. On initial appeal, the Supreme Court remanded for inquiry into potential juror misconduct related to knowledge of Defendant’s prior conviction, but the trial court found no misconduct. On renewed appeal, the Court affirmed the conviction and sentence. Defendant argued that the delayed indictment violated his constitutional rights, but the Court held he failed to show purposeful delay or actual prejudice. His change of venue claim was also rejected because the publicity did not create a “carnival-like atmosphere,” nor did he show actual bias. The Court upheld the exclusion of a statement describing the perpetrator as a different ethnicity, reasoning it was not clearly an excited utterance and discrepancies in identification were admitted via police reports. Similarly, the admission of a suspect sketch was upheld for the limited purpose of showing police publication. The Court affirmed exclusion of a defense witness due to memory issues, and rejected admission of unverifiable phone records as inadmissible hearsay. Renewed claims of juror misconduct were denied, as the juror only remembered that a previous murder occurred, not Defendant’s conviction. Defendant challenged DNA evidence, but the Court found the State’s chemist complied with proper procedures as established during a Daubert hearing. Daubert v. Merrel Dow Pharms., Inc., 509 U.S. 579 (1993). It also upheld admission of testimony about financial arguments with the victim as a present sense impression, and an inmate’s testimony about Defendant’s confession as a party admission. The Court found no abuse of discretion in admitting a late-disclosed timeline, noting the trial court mitigated any harm by delaying admission. Though the Court found error in the jury instruction on “cold-and-calculating” conduct, it deemed it harmless. Victim impact statements were also properly admitted. Finally, the Court concluded the jury acted within its discretion in finding aggravating factors and sentencing Defendant to death, and affirmed the conviction and sentence.

Summary of Case Context & HoldingIn this case the Supreme Court found that a statutory requirement of lifetime satellite based monitoring (SBM) for an aggravated sex offender did not violate the Fourth Amendment prohibition on unreasonable searches and seizures. As applied to the Defendant in this case—who had pled guilty to and been convicted of forcible rape, kidnapping, and robbery with a dangerous weapon—the Supreme Court held that lifetime SBM was a reasonable warrantless search. The Court noted that there is a compelling governmental interest in preventing and prosecuting future crimes committed by sex offenders and that interest is promoted by the SBM program. The Supreme Court reasoned that the governmental interest outweighed the Defendant's privacy interest under the Fourth Amendment.

Summary of Case Context & HoldingDefendant, a 17 year old minor, was charged with two counts of sexual intercourse without consent. He was charged with one instance that occurred at age 17 and one that occurred at age 16. Even though in one instance he was 16, the State filed the case directly in the district court. Defendant sought to have the charge transferred to youth court, but the district court denied the transfer motions. Defendant pled guilty to one count and was sentenced to 50 years in prison with ten years suspended. While the district court agreed that transferring the case to youth court would be in Defendant's best interest, it concluded that the nature of the offense and the interests of the community’s protection weighed against transferring the case. On appeal, the Court addressed the transfer and sentence. The Court held that the district court may transfer the case to youth court only if it finds, by a preponderance of the evidence, that: (a) a youth court proceeding and disposition will serve the interests of community protection; (b) the nature of the offense does not warrant prosecution in district court; and (c) it would be in the best interests of the youth if the matter was prosecuted in youth court. The record contained substantial credible evidence to support the district court's findings. Accordingly, the Court concluded that the district court did not abuse its discretion by denying the request to transfer to youth court. However, the Court concluded that the district court erred by not including the requirements found in 41-5-2503(1), MCA, in Defendant's sentence. Those requirements include: (b) retain jurisdiction over the case until the criminally convicted youth reaches the age of 21; and (c) order the department to submit a status report to the court, county attorney, defense attorney, and juvenile probation officer every 6 months until the youth reaches the age of 21. The report must include a recommendation from the department regarding the disposition of the criminally convicted youth. On remand, because Defendant turned 21 while the appeal was pending, the district court must review his sentence pursuant to § 41-5-2510, MCA. Under § 41-5-2510, MCA, a party may request a hearing to review a sentence imposed anytime before the youth reaches 21 years of age except for offenses punishable by death or life imprisonment or when a sentence of 100 years can be imposed. After review, the court will determine whether to hold a criminally convicted youth sentence review hearing. If so, the hearing must be held within 90 days of the filing of the request or determination. The sentencing court will review the pertinent records and information including criminal, social, and psychological records/evidence. Victim's statements are also reviewed. In this instance, the Defendant was convicted of a crime as an adult. The district court could have sentenced him to 100 years for the crime (though the Court did not impose that sentence). Therefore, under a plain reading of § 41-5-2510, MCA, a request for hearing to review the sentence could not be made prior to him turning 21. Under § 41-5-2503(2) however, if a hearing has not been requested under 41-5-2510, the district court must review the sentence under 41-5-2510 before the defendant reaches age 21 within 90 days of the request or determination of the requirement. To prohibit the review of a Defendant's sentence would defeat the statutory scheme.

Summary of Case Context & HoldingAppellant was convicted in the district court of first-degree murder and attempted first-degree murder, based on Appellant’s aiding and abetting an attempt to retaliate against a rival gang member for shooting Appellant’s younger brother. Appellant appealed arguing: (1) the district court’s requirement that members of the public display photographic identification in order to attend Appellant’s trial constituted a partial courtroom closure which impaired his right to a public trial; (2) the district court’s exclusion of certain evidence supporting an alternative motive of accomplice witnesses was erroneous, harming Appellant; (3) the district court’s admission of gang expert testimony identifying Appellant as a gang member was erroneous, harming Appellant; (4) the district court’s jury instructions on aiding and abetting liability were plainly erroneous; (5) the district court’s failure to give a limiting instruction sua sponte regarding Appellant’s prior convictions was plainly erroneous; (6) the district court violated Appellant’s right to a speedy trial; (7) the district court’s admission into evidence of a handwritten note seized from Appellant’s jail cell was erroneous; (8) Appellant did not waive review of whether the admission into evidence of jail call recordings was erroneous; and (9) the cumulative effect of the foregoing errors, even if individually harmless, deprived Appellant of a fair trial. The Supreme Court of Minnesota rejected each of the claims. Of particular note, the Supreme Court held that the district court's attempt to prevent disruptions by persons in the gallery by issuing a list of ‘‘basic rules’’ for spectators at trial, including the requirement to show photographic identification before being allowed entry into the district courtroom, was not a closure (which, if unjustified, would be unconstitutional in the United States and Minnesota per Waller v. Georgia, 467 U.S. 39 (1984)) as the requirement was too trivial to constitute a true closure as there was no evidence that a significant portion of the public was unable to attend due to the identification requirement. Justice Page dissenting took the position that requiring members of the public to provide photo identification to enter a courtroom during trial is a bridge too far (and, accordingly, prior Minnesota precedent that allows for this should be revisited).

Summary of Case Context & HoldingOn appeal for being convicted and sentenced to death for murdering his mother, the Defendant argued, among other things, that statements he made during interrogation should be suppressed, that his counsel was ineffective because they failed to object to certain testimony, and that the prosecutor engaged in misconduct by stating a claim that was unsupported in opening statement. The Supreme Court held, among other things, that the Defendant validly waived his right to counsel during interrogation with police detective; defense counsel was not ineffective in attempting to rehabilitate prospective jurors opposed to death penalty; and prosecutor did not commit misconduct because his unsupported claim in opening statement did not render the Defendant's trial so fundamentally unfair as to deny Defendant due process.

Summary of Case Context & HoldingThis case concerns the "private-search doctrine" and warrantless searches. The private search doctrine allows the government to use evidence of criminal conduct that was found in someone's personal effects or on their person, even if a warrant for a search was not granted, when a private actor found the evidence. In this case, a detective conducted a warrantless search of the Defendant's USB drive, following a search of a portion of the drive by Defendant's girlfriend (a private individual). The girlfriend previously looked through the contents of the USB until she saw a picture of her nine-year-old granddaughter exposed from the waist up. The girlfriend took the thumb drive to a detective who searched through it to locate the image. During that search, the detective discovered images on the drive that appeared to be child pornography. The Defendant was indicted for related sexual exploitation of a minor charges. At trial, the Defendant's motion to suppress the USB evidence on Fourth Amendment grounds was denied. The Defendant appealed. The appellate court held that the warrantless search violated the Defendant's Fourth Amendment rights. The Supreme Court affirmed, reasoning that the girlfriend conducted only a limited search of the USB. The Supreme Court viewed the USB as a container. As such, the Defendant had a reasonable expectation of privacy regarding what could be seen as a "closed container," so the detective was not permitted to search the entire USB under the private search doctrine without a warrant.

Summary of Case Context & HoldingTerry, the Defendant, was pulled over for two minor traffic infractions while driving a rental truck. By the time the Defendant was able to pull the truck over in the lot of a gas station, officers had already determined that the truck was a rental and had not been reported stolen. Two officers then removed the Defendant from the truck at gunpoint and demanded his license and ID. The officer searched the truck's glove compartment and claims he saw contraband sticking out from under the front passenger seat. The Defendant argued that his rental truck should never have been searched, and that any exemption to the warrant requirement that would have allowed the search is unconstitutional. Although the trial court denied the Defendant's motion to suppress the handgun, the Appellate Division reversed and vacated the Defendant's conviction. The Appellate Division held that the search was unreasonable because the police did not give the Defendant the opportunity to produce the truck's registration. The Supreme Court, however, reversed again, holding that: (i) after a driver is given the opportunity to present a vehicle's ownership credentials but is unwilling or unable to do so, an officer may engage in a pinpointed search limited to those places, such as a glove box, where proof of ownership is ordinarily kept; and (ii) evidence in this case supported the finding that the Defendant was unwilling or unable to produce proof of ownership of the vehicle he was driving, justifying the officer's limited search of the vehicle's glove compartment, pursuant to the registration search exception to the warrant requirement, for proof of ownership. The Supreme Court determined that the Defendant was afforded a sufficient opportunity to present the requested documentation prior to the search. This opinion implies that vehicles may not be subject to the same level of Fourth Amendment protection as physical structures, such as one's home, and any evidence retrieved from a vehicle search will be relatively difficult to suppress by a defendant.

Summary of Case Context & HoldingDefendant physically assaulted his girlfriend, causing numerous injuries. He sought to dismiss his Partner or Family Member Assault (PFMA) charge (a charge alleging that a defendant has assaulted a family member or a current or past romantic partner) on the ground that the statute under which he was charged violated his right to equal protection because it did not apply to persons in same-sex intimate relationships. At the time of Defendant's arrest, the statute defined “partners,” in part, as “persons who have been or are currently in a dating or ongoing intimate relationship with a person of the opposite sex.” Defendant acknowledged that he was not in a same-sex relationship, but argued that the statute exposed him to greater punishment than a same-sex abuser would face if charged with simple assault and argued that the statute facially discriminated against similarly-situated classes without justification. The Court accepted Defendant's argument that the former version of the statute under which he was charged violated equal protection by defining "partners" as "persons who have been or are currently in a dating or ongoing intimate relationship with a person of the opposite sex," however, given that the statute contained a severability clause, the Court held that severing the phrase "with a person of the opposite sex" would not frustrate the purpose or disrupt the integrity of the law. Thus, the Defendant's motion to dismiss was denied.

Summary of Case Context & HoldingDefendant was arrested and tried for a double homicide. After a 10 day trial, a jury found Defendant guilty of first degree murder and sentenced him to death. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence recovered during a traffic stop and any fruit of that search due to Defendant's erratic driving behavior in the presence of police officers; (2) the trial court did not err in the way it conducted voir dire as the questioning was deemed fair and impartial under Morgan v. Illinois, 504 U.S. 719 (1992); (3) Defendant's evidentiary challenges were without merit because the use of such evidence did not materially affect how the State met its burden of proof; (4) one instance of prosecutorial error occurred, but the error was not prejudicial; (5) any error during the aggravation phase was harmless because any evidence the State used was otherwise admissible; and (6) Defendant's challenges to the death penalty were unavailing. Even if they were, the error was harmless because the jury not only found Defendant guilty of felony murder, but also found him guilty of premeditated murder of two victims. The death penalty was also imposed for those victims. Therefore, any error was not prejudicial.

Summary of Case Context & HoldingPolice responded to complaints about Defendant urinating and masturbating in the middle of a public park. Defendant was diagnosed with schizoaffective disorder and suffered from substance abuse issues, but was deemed fit to stand trial. Defendant pled guilty to the charge of felony criminal endangerment. He received a five-year suspended sentence to the Department of Public Health and Human Services (DPHHS) and probation with the Department of Corrections (DOC). Defendant continued to fail to comply with the conditions of his probation. As a result, he was sanctioned to 60 days in the "Mental Health Unit" at the Sanction, Treatment, Assessment, Revocation, and Transition (START) facility. When the district court confirmed Defendant's new sentence, he was not given credit for the 60-day period that he served as a sanction at the START facility, finding that he was not entitled to receive credit because he was "not incarcerated pursuant to § 46-18-203(7)(b), MCA." The Court held that the district court's new sentence was well within the ten-year statutory maximum that could have been imposed for the crime of criminal endangerment and the length of Defendant's new sentence was for less time than his original suspended sentence length of five years. Accordingly, the Court determined that Defendant's sentence was not an "illegal sentence." However, the Court explained that Section 46-18-203(7)(b), MCA, provides that, upon revoking a criminal defendant's suspended sentence and imposing a new sentence (as occurred here), "[c]redit must be allowed for time served in a detention center or for home arrest time already served." The Court found that the START facility was a detention center under the plain meaning of Mont. Code Ann. § 7-32-2241(1) as inmates were not free to leave until they served their sanction period and START implemented a strict security protocol. The Court remanded the proceedings for Defendant to receive credit for time served in the amount of the 60 days for his time served at the START facility.

Summary of Case Context & HoldingDefendant, who was tried as a juvenile offender in adult court, appealed from the judgment and order convicting him of first-degree reckless injury and attempted robbery with threat of force, and denying his motion for postconviction relief. Wisconsin's Juvenile Justice Code gives adult courts exclusive original jurisdiction over juveniles who are alleged to have committed certain serious offenses. Wis. Stat. § 938.183(1). The statute also gives exclusive original jurisdiction over juveniles who are alleged to have attempted to commit a violation of Wis. Stat. § 940.01 (first-degree intentional homicide). Wis. Stat. § 938. 183(1)(am). A juvenile, who is charged in adult court with a violation of first-degree intentional homicide, is entitled to a preliminary examination under which the court must find probable cause for the adult court to retain exclusive original jurisdiction of the juvenile. Here, the issue is whether the record demonstrates that the adult court made a sufficient probable cause determination to retain exclusive original jurisdiction. The circuit court, which is the adult court in this case, found probable cause to believe that juvenile committed “a felony" (without specifying the felony). The juvenile appealed the circuit court's decision to the court of appeals, which later affirmed the circuit court's judgment of conviction. The Supreme Court held that: First, if an adult court's determination of probable cause in a preliminary examination of a juvenile charged in adult court relates to an unspecified felony and the facts are undisputed, the appellate court may review the record independently to determine whether the adult court implicitly found probable cause to believe that the juvenile committed the violation of which he or she was accused. The Supreme Court acknowledged that the adult court did not specifically refer to the charged felony, but "the totality of the circumstances leaves no doubt that there was probable cause to believe [defendant] attempted first-degree intentional homicide." The Supreme Court heavily relied on the fact findings in the preliminary hearing to support its holding. Second, the circuit court, in finding probable cause to believe that a juvenile committed “a felony,” found probable cause to believe that the juvenile committed attempted first-degree intentional homicide, as necessary to retain exclusive original jurisdiction over the juvenile. Based on the totality of the circumstances, the Supreme Court determined that the records demonstrates that the circuit court had implicitly found probable cause.

Summary of Case Context & HoldingDefendant and Co-Defendant, former police officers, were convicted of five of six counts following a joint trial in the superior court: (1) second-degree official misconduct; (2) making false statements; (3) falsifying records, and two other unidentified charges following an automobile stop. The automobile stop resulted in an arrest following the arrestee's refusal to get out of the car. At trial, the State asked the arrestee why he had not gotten out of the car. The arrestee referenced prominent instances of police brutality against black men. The State also called a lay witness who said that the officers' actions "appeared to have been criminal." The Defendant alleged that the trial court erred in admitting prejudicial and lay opinion testimony as to Defendant's guilt, and also erred in sentencing Defendant to a five year term of imprisonment with five years of parole ineligibility. The Appellate Division affirmed the trial court's ruling. Defendant appealed. The Supreme Court held that: (1) opinion testimony of the lieutenant with the Internal Affairs Division that Defendant's actions “appeared to have been criminal” constituted impermissible lay opinion on ultimate issue of guilt; (2) the lieutenant's opinion testimony did not constitute plain error; (3) the probative value of arrestee's testimony regarding multiple high profile cases of police brutality involving police shootings of African Americans was substantially outweighed by danger of undue prejudice; (4) the trial court's error in failing to conduct evaluation of the probative value of arrestee's testimony against danger of undue prejudice, and in failing to strike testimony, was harmless; (5) the interest of justice did not warrant a downgrade of sentence for second-degree official misconduct to third-degree official misconduct; and (6) Defendant was not entitled to reduction or waiver of minimum sentence for second-degree official misconduct. The Supreme Court ultimately found that although the trial court erred by admitting prejudicial and lay opinion testimony, the evidence against the Defendant was overwhelming, so any error was harmless.