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. Strudwick, 864 S.E.2d 231 (N.C. 2021)
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North Carolina | 2021 | Criminal Justice |
State:
North Carolina
Year:
2021
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 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.
Link to Opinion
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State v. Strong, 555 P.3d 537 (Ariz. 2024)
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2024 | Criminal Justice, Death Penalty, Access to Justice |
State:
Year:
2024
Topics:
Criminal Justice, Death Penalty, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
After 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.
Link to Opinion
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State v. Stietz, 895 N.W.2d 796 (Wis. 2017)
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Wisconsin | 2017 | Criminal Justice, Police Misconduct and Bias |
State:
Wisconsin
Year:
2017
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Steele, 3 N.E.3d 135 (Ohio 2013)
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Ohio | 2013 | Criminal Justice, Police Misconduct and Bias |
State:
Ohio
Year:
2013
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
A 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.
Link to Opinion
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State v. Stavish, 868 N.W.2d 670 (Minn. 2015)
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Minnesota | 2015 | Criminal Justice, Access to Justice |
State:
Minnesota
Year:
2015
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Minnesota 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.
Link to Opinion
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State v. Spreitz, 561 P.3d 393 (Ariz. 2025)
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Arizona | 2025 | Criminal Justice, Death Penalty |
State:
Arizona
Year:
2025
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The 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.
Link to Opinion
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State v. Spady, 354 P.3d 590 (Mont. 2015)
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Montana | 2015 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2015
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
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.”
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.”
Link to Opinion
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State v. Sowell, 71 N.E.3d 1034 (Ohio 2016)
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Ohio | 2014 | Criminal Justice, Access to Justice |
State:
Ohio
Year:
2014
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Soto-Fong, 474 P.3d 34 (Ariz. 2020)
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Arizona | 2020 | Criminal Justice, Juvenile Justice |
State:
Arizona
Year:
2020
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
This 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.
Link to Opinion
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State v. Smith, 876.N.W.2d 310 (Minn. 2016)
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Minnesota | 2016 | Criminal Justice, Access to Justice |
State:
Minnesota
Year:
2016
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant 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.
Link to Opinion
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State v. Smith, 846 S.E.2d 492 (N.C. 2020)
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North Carolina | 2020 | Education, Gun Control in Schools/School Safety |
State:
North Carolina
Year:
2020
Topics:
Education, Gun Control in Schools/School Safety
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Smith, 475 P.3d 558 (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 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
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State v. Smith, 276 A.3d 1114 (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 & 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Detectives 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.
Link to Opinion
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State v. Smart, 889 S.E.2d 573 (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 & 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Jon 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.
Link to Opinion
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State v. Smart, 289 A.3d 469 (N.J. 2023)
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New Jersey | 2023 | Criminal Justice, Police Misconduct and Bias |
State:
New Jersey
Year:
2023
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Officer 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.
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State v. Slocumb, 827 S.E.2d 148 (S.C. 2019)
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South Carolina | 2019 | Criminal Justice, Death Penalty, Civil Rights |
State:
South Carolina
Year:
2019
Topics:
Criminal Justice, Death Penalty, Civil Rights
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
At 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.
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State v. SisterSong Women of Color Reprod. Just. Collective, 894 S.E.2d 1 (Ga. 2023)
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Georgia | 2023 | Health Care, Reproductive Rights/Abortion |
State:
Georgia
Year:
2023
Topics:
Health Care, Reproductive Rights/Abortion
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Reproductive 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.
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State v. Sisco, 373 P.3d 549 (Ariz. 2016)
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Arizona | 2016 | Criminal Justice, Police Misconduct and Bias |
State:
Arizona
Year:
2016
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingPolice officers 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Police 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.
Link to Opinion
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State v. Simpkins, 838 S.E.2d 439 (N.C. 2020)
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North Carolina | 2020 | Criminal Justice, Access to Justice |
State:
North Carolina
Year:
2020
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
This 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.
Link to Opinion
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State v. Shuler, 861 S.E.2d 512 (N.C. 2021)
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North Carolina | 2021 | Criminal Justice |
State:
North Carolina
Year:
2021
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Shata, 868 N.W.2d 93 (Wis. 2016)
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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 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Serrato, No. CR-24-0264, 2025 WL 1387711 (Ariz. May 14, 2025)
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Arizona | 2025 | Criminal Justice, Access to Justice |
State:
Arizona
Year:
2025
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Serna, 331 P.3d 405 (Ariz. 2014)
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2014 | Criminal Justice, Police Misconduct and Bias |
State:
Year:
2014
Topics:
Criminal Justice, Police Misconduct and Bias
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Sanders, 912 N.W.2d 16 (Wis. 2018)
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Wisconsin | 2018 | Criminal Justice, Juvenile Justice |
State:
Wisconsin
Year:
2018
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
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).
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Justice Vote Breakdown
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Summary of Case Context & Holding
After 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).
Link to Opinion
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State v. San Antonio Indep. Sch. Dist., 677 S.W.3d 915 (Tex. 2023)
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Texas | 2023 | Labor, Employment, & Economic Justice, CARES Act and Pandemic Relief |
State:
Texas
Year:
2023
Topics:
Labor, Employment, & Economic Justice, CARES Act and Pandemic Relief
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The 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.
Link to Opinion
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State v. Salas Gayton, 882 N.W.2d 459 (Wis. 2016)
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Wisconsin | 2016 | Criminal Justice, Access to Justice |
State:
Wisconsin
Year:
2016
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Following 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.
Link to Opinion
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State v. Rodriguez, 814 S.E.2d 11 (N.C. 2018)
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North Carolina | 2018 | Criminal Justice, Death Penalty |
State:
North Carolina
Year:
2018
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was convicted of first-degree murder and sentenced to death. 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant was convicted of first-degree murder and sentenced to death. 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.
Link to Opinion
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State v. Robinson, 846 S.E.2d 711 (N.C. 2020)
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North Carolina | 2020 | Criminal Justice, Death Penalty |
State:
North Carolina
Year:
2020
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 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.
Link to Opinion
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State v. Robinson, 509 P.3d 1023 (Ariz. 2022)
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Arizona | 2022 | Criminal Justice, Death Penalty |
State:
Arizona
Year:
2022
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The 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.
Link to Opinion
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State v. Robinson, 160 A.3d 1 (N.J. 2017)
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New Jersey | 2017 | Criminal Justice, Access to Justice |
State:
New Jersey
Year:
2017
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The 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.
Link to Opinion
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State v. Roberts, 998 N.E.2d 1100 (Ohio 2013), rev'd and remanded, Ohio v. Clark, 576 U.S. 237 (2015)
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Ohio | 2013 | Criminal Justice, Death Penalty |
State:
Ohio
Year:
2013
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The 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.
Link to Opinion
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State v. Roberson, 935 N.W.2d 813 (Wis. 2019)
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Wisconsin | 2019 | Criminal Justice, Access to Justice |
State:
Wisconsin
Year:
2019
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Rick, 835 N.W.2d 478 (Minn. 2013)
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Minnesota | 2013 | LGBTQ+ Rights, LGBTQ+ Discrimination, Health Care, Health Care Discrimination |
State:
Minnesota
Year:
2013
Topics:
LGBTQ+ Rights, LGBTQ+ Discrimination, Health Care, Health Care Discrimination
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Rick, 835 N.W.2d 478 (Minn. 2013)
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Minnesota | 2013 | Health Care, Public Health |
State:
Minnesota
Year:
2013
Topics:
Health Care, Public Health
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
Link to Opinion
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State v. Reim, 323 P.3d 880 (Mont. 2014)
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Montana | 2014 | Criminal Justice, Access to Justice |
State:
Montana
Year:
2014
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & HoldingDefendant was charged with 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendant 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.
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State v. Reek, 942 N.W.2d 148 (Minn. 2020)
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Minnesota | 2020 | Criminal Justice, Access to Justice |
State:
Minnesota
Year:
2020
Topics:
Criminal Justice, Access to Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Appellant 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.
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State v. Reed, 838 S.E.2d 414 (N.C. 2020)
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North Carolina | 2020 | Criminal Justice |
State:
North Carolina
Year:
2020
Topics:
Criminal Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
The 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.
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State v. Ramseur, 843 S.E.2d 106 (N.C. 2020)
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North Carolina | 2020 | Criminal Justice, Death Penalty |
State:
North Carolina
Year:
2020
Topics:
Criminal Justice, Death Penalty
Justice Vote Breakdown
Justices Political Affiliation
Summary of Case Context & 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
In 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.
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State v. Radel, 267 A.3d 426 (N.J. 2022)
State v. Terres, 267 A.3d 426 (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 & 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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
These 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.
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State v. Purcell, 526 P.3d 146 (Ariz. 2023)
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Arizona | 2023 | Criminal Justice, Juvenile Justice |
State:
Arizona
Year:
2023
Topics:
Criminal Justice, Juvenile Justice
Justice Vote Breakdown
Justices Political Affiliation
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.
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Justice Vote Breakdown
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Summary of Case Context & Holding
Defendants 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.
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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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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. 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. 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. 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. 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. 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.
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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.
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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. 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.
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