State Supreme Court Data Tracker

Summary of Case Context & HoldingDefendant, a Sheriff's Deputy, was charged with mistreating prisoners, a felony offense, pursuant to § 45-5-204, MCA in connection with an incident that took place on February 9, 2011. The alleged victim was a female juvenile at the time of the incident, and her parents had requested law enforcement assistance in transporting her to a residential treatment center. While at the police station, the victim was handcuffed and shackled, and after a verbal altercation, Defendant "pushed her against the wall, banging her head." Defendant subsequently moved to dismiss the charge, contending that the alleged victim was not a “prisoner” under that statute. The district court agreed, holding that a “prisoner” under § 45-5-204, MCA, means only “an individual who is serving a sentence at the State prison or another State facility as the result of a conviction.” The district court dismissed the charge against Defendant because the victim was a juvenile, she had not been convicted of an offense, and she was not being held in a State facility. The Court reversed holding that the word “prisoner” is one in common usage with a common understanding, and that it was clear from the ordinary and common understanding of the word that “prisoner” includes a person detained by law enforcement officers, confined to a small room, and shackled hand and foot. Further, the Court explained that nothing in the statute or elsewhere in Montana law precludes application of the statute to the facts alleged in the information (i.e., a formal criminal charge which begins a criminal proceeding in the courts). Accordingly, the Court held that the district court's conclusion that the victim was not a “prisoner” was incorrect. The case was reversed and remanded.

Summary of Case Context & HoldingDefendant who had been charged with murder, conspiracy, and aggravated assault and ordered detained in February 2020, shortly before the outbreak of the COVID-19 pandemic, sought leave to appeal the trial court's orders excluding time from the speedy-trial calculation under the Criminal Justice Reform Act (CJRA). The CJRA, which went into effect in 2017, replaced New Jersey's prior system of pre-trial release with a risk-based system that allowed judges to detain high-risk defendants pre-trial. The CJRA contains a two-year cap that requires defendants to be released from jail after a hearing if the prosecutor is not ready to proceed. Due to the pandemic delays and other delays caused by counsel, Defendant's trial was not scheduled until April 2022. The issue before the New Jersey Supreme Court was whether the Defendant's right to a speedy trial was violated given the delays caused, in part, by pandemic restrictions. The Court explained that defendants have the right to be released two years after a judge orders them detained, excluding delays attributable to the defendant, if the prosecutor is not ready to proceed to trial. N.J.S.A. 2A:162-22(a)(2)(a). However, the statute is silent about what happens if the parties are ready but there are not enough courtrooms or judges to try the case. In addressing that dilemma, the Court attempted to balance the relevant interests in a way that comports with defendants’ rights under the CJRA. In this case, the delays were largely due to the pandemic, an event over which the trial court and counsel had little control and, ultimately, the prosecution still announced it was ready for trial within the two-year mark. Therefore, the Court found there was no violation of the CJRA. The Court held that: (1) the prosecution sufficiently demonstrated that it was ready to proceed to trial once the CJRA's speedy-trial provision's two-year cap between detention order and trial had run; (2) Defendant's statutory right under the CJRA to a speedy trial were not violated; and (3) the trial court could sua sponte issue orders excluding time from the speedy-trial clock under the CJRA due to the COVID-19 pandemic and its consequences because nothing in the statute or court rules bar such judicial action. Nevertheless, the Court provided guidance for courts going forward, encouraging trial judges to create a clearer record regarding the State's readiness and directing courts to hold a hearing approximately 30 days before the two-year mark where the court will ask the State for a statement of readiness. The State's statement will be understood to encompass multiple elements: discovery is complete, there are no more substantive motions, the indictment is final, and the State's witnesses are generally available. The trial court should also consult with a supervisory judge who coordinates trials and, if the parties are ready, but trial cannot start before the two-year cap, trial judges must schedule monthly conferences rather than delaying trial for months. The Court also asked that prosecutors and defenders notify their supervisors of trial dates to ensure counsel will be present. Further, where judicial vacancies remain at high levels, the Court indicated it may be necessary to reassign judges.

Summary of Case Context & HoldingFollowing Defendant's arrest, the State sought and the grand jury issued a subpoena to a wireless telephone service provider requesting subscriber information associated with Defendant's cell phone number, as the cell phone number was the mode of contact that Defendant used for the alleged controlled drug buys that led to Defendant's arrest. The subpoena sought customer and billing records, call-detail records identifying the phone numbers of all incoming and outgoing calls, as well as the date, time, and duration of those calls. Defendant's motion to quash the subpoena was granted, after the lower court found that a communications data warrant is needed to obtain telephone billing records, which requires a showing of probable cause. The New Jersey Supreme Court explained that telephone billing records reveal details of one's private affairs that are similar to what bank and credit card records disclose, and that therefore such information should be afforded the same level of constitutional protection and be available only if they are relevant to an ongoing criminal investigation. More intrusive records, however, such as cell phone location information, are entitled to a greater level of protection and continue to require a search warrant. Therefore, the Court held that billing records should be available based on a lower standard of relevance, as opposed to the probable cause standard generally required for search warrants.

Summary of Case Context & HoldingAppellant was charged with two counts of first-degree criminal sexual conduct and four counts of second-degree criminal sexual conduct. During jury selection, the State used a peremptory strike to excuse a prospective juror who self-identified as multi-racial. Appellant challenged the strike on the grounds that the sole reason for the challenge was that the prospective juror was the only nonwhite person on the panel. The State argued that there were three race-neutral reasons for the strike: (i) a prior flag on the individual from law enforcement; (ii) the individual's age of 20; and (iii) the fact that the individual had been glaring at the prosecutor throughout the jury selection process. Appellant's challenge was denied. After trial, Appellant was found guilty. Appellant argued that the district court erred by overruling Appellant's challenge to the strike, because reason (i) and (iii) for the strike offered by the State were not connected to the case, and were instead a pretext for discrimination. The Supreme Court affirmed holding that while the State's argument that there had been a law enforcement flag was not connected to the case, the fact that the prospective juror was glaring at the prosecutor was both connected to the case, and not merely a pretext for a discriminatory motive.

Summary of Case Context & HoldingAppellant was indicted for several shooting-related offenses. In its findings of fact, the court made a finding concerning business closures at the outset of the COVID-19 pandemic that was not supported by the record, and used this finding as part of its assessment of Appellant's credibility. Appellant was found guilty of first-degree premeditated murder and attempted second degree murder, and appealed alleging that the pandemic-related finding based on facts not in the record reflected a structural error that deprived him of an impartial finder of fact. The Court held that the pandemic-related finding did not warrant a new trial because other facts attested to at trial rendered the pandemic-related fact unneeded to convict.

Summary of Case Context & HoldingA new Texas law, Texas Health & Safety Code Section 161.702, prohibits certain medical treatments for children if administered for the purpose of transitioning a child's biological sex or affirming the child's perception of their sex which is inconsistent with the child's biological sex. Prior to the passage of the law on September 1, 2023, parents of children with gender dysphoria, physicians, and affiliated groups sued the state to enjoin its enforcement, alleging that the law is facially unconstitutional. Plaintiffs presented three arguments. First, parents of the children argued that prohibiting use of these treatments for gender dysphoria unconstitutionally deprives parents of their parental rights and responsibility over their children. Second, physicians that perform gender dysphoria procedures argued that they have property rights in their physician licenses and that prohibiting these medical treatments unconstitutionally deprives them of the use of their license. Third, Plaintiffs argue that this prohibition of treatment discriminates against transgender adolescents that have gender dysphoria because of their sex, sex stereotypes, and transgender status. The trial district court held that the law likely violates the Texas Constitution and temporarily enjoined the law's enforcement. The case went on direct appeal, concerning the temporary injunction, to the Supreme Court of Texas. The Supreme Court of Texas held that the Texas Legislature made a permissible, rational policy choice to limit the types of available medical procedures for children. The Court reasoned that the Texas Legislature has express constitutional authority to regulate the practice of medicine in the state. With respect to Plaintiffs' arguments, first, the Court held that the law does not unconstitutionally deprive parents of their parental rights. The Court reasoned that a parent's right to exercise control over decision-making for their children has limits and the state's regulation and control of the medical practice is an outweighing competing interest. Further, a parent's interest in obtaining medical care for their children is only extended to legally available medical treatments. The legislature's power to regulate the medical practice, especially for novel treatments of novel conditions, should not face any heightened scrutiny. Second, the Court held that the law does not deprive health care professionals of any alleged property right. The Court reasoned that a physician's license is a property interest that is subject to regulation and is not absolute. The practice of medicine is a privilege and not a natural rights of individuals. Legislative regulation of this privilege is subject to control as necessary to protect the public interest. Third, with respect to Plaintiff's last argument that this prohibition discriminates against transgender adolescents, the Court ruled that the law does not deny equality under the law because it does not establish unequal treatment for males or females. The prohibition does not treat any person differently from those in a similar situation because of that person's sex.

Summary of Case Context & HoldingThis case answers the question of whether the good-faith exception to the exclusionary rule articulated in Davis v. U.S., 564 U.S. 229 (2011), according to which evidence obtained during a search conducted in reasonable reliance on binding precedent is not subject to the exclusionary rule, should apply in Minnesota. Appellant was convicted of third-degree driving while impaired (DWI). Officers responded to a single-vehicle accident on a rural road, where the occupants had fled. They (a husband and wife) were later found in their home nearby, both with injuries, and police determined the wife (the Appellant) to have been the driver. The officers observed that the Appellant had slurred speech, an unsteady gait, and red eyes, and failed field sobriety tests. After declining a breath test, Appellant was arrested and transported to a hospital for a blood draw. The officer who facilitated the blood draw did not read the Minnesota implied consent advisory, and sought neither consent nor a warrant for the blood draw. Appellant's alcohol concentration measured at .23 approximately 2 hours after driving. At trial, the district court admitted test results showing Appellant’s alcohol concentration that were based on a warrantless blood draw. While Appellant’s case was on direct appeal, the U.S. Supreme Court decided Missouri v. McNeely, 569 U.S. 141 (2013), which held that the dissipation of alcohol in the blood does not create a single-factor exigency justifying a warrantless blood draw of suspected drunk drivers. Appellant thus challenged the blood draw as unconstitutional under McNeely. The Supreme Court of Minnesota held that McNeely applies to cases on direct review at the time of decision, but also held that the test results from Appellant’s warrantless blood draw, even if unconstitutionally obtained, did not need to be suppressed because the officer who facilitated the blood draw acted in objectively reasonable reliance on binding appellate precedent, having noticed that Appellant had an unsteady gait and that her eyes were bloodshot and weary, which indicated probable cause that Appellant was intoxicated when she caused the accident. Conviction was therefore affirmed.

Summary of Case Context & HoldingDefendant shot his two toddler sons in the head and attempted suicide after his wife filed for divorce. He was charged with and convicted of two counts of first-degree murder. The jury found three aggravating factors: that the murders were especially heinous, committed on the same day, and involved victims under fifteen. Defendant was sentenced to death. On automatic appeal, the Supreme Court affirmed. The Court held that Defendant’s admissions to the police were admissible under the New York v. Quarles, 467 U.S. 649 (1984) public safety exception to Miranda v. Arizona, 384 U.S. 436 (1966), as officers were assessing the scene for safety and to render aid. Evidence of suicide notes, financial struggles, and harassment of his ex-wife were properly admitted to show intent or motive, not improper character evidence. The Court found error in excluding expert testimony on Defendant’s impulsivity and prescription drug use, but deemed both harmless given the strong evidence of premeditation. The Court also rejected the claim that a mistrial was warranted after a State expert described drug levels as “therapeutic,” since the testimony was relevant at trial. Though it found error in the jury instruction suggesting aggravating factors could be based solely on familial relationship, it held the error harmless due to other supporting evidence. The Court upheld the exclusion of a defense prison expert’s speculative testimony about child-killers' treatment, and found no due process violation in neighbors’ rebuttal testimony about the emotional impact of the murders. Finally, the Court affirmed both the restitution order and the jury’s death sentence.

Summary of Case Context & HoldingAppellant was charged with second-degree sale of a controlled substance and third-degree possession of a controlled substance, after police found heroin in a rental car that Appellant was driving. Prior to trial, Appellant moved to suppress the heroin on the ground that the police unlawfully searched the car without a warrant. Because (i) the officer had received a tip regarding a plan for an individual with a particular description to deliver heroin from a confidential reliable informant he had previously worked with and found reliable; (ii) the officer identified the passenger in a vehicle as the Appellant; and (iii) Appellant was behaving in a way that appeared to the officer that he was waiting for a potential narcotics customer, the district court denied Appellant’s motion to suppress the heroin, concluding that Appellant’s arrest was supported by probable cause and that the vehicle search was lawful under both the automobile exception and the search-incident-to-arrest exception. The Supreme Court of Minnesota held that on the basis of the facts established at the district court trial, the officer had probable cause to believe that contraband would be found in the Appellant’s car, and thus the warrantless search was justified under the automobile exception to the search warrant requirement.

Summary of Case Context & HoldingWhile Defendant was on probation, a probation officer arrested Defendant for violating several conditions of his probation. The officer looked through incriminating text messages and photos on Defendant's phone. The State subsequently indicted Defendant for sexual conduct with a minor. Defendant moved to suppress the evidence gathered from the cell phone search. The trial court granted the motion. The court of appeals reversed. The Supreme Court held that the plain meaning of "property" in one of Defendant's conditions of supervised probation included his cell phone. Additionally, the Court held that Riley v. California, 573 U.S. 373 (2014) (holding that police officers may not, without a warrant, search the digital data of a cell phone taken from an individual who has been arrested), did not vary that meaning and accordingly the search was permissible. Under the totality of the circumstances, the officer's search of Defendant's cell phone was reasonable and did not violate the Fourth Amendment. Defendant was on a supervised probation and subject to conditions which authorized a warrantless search of his property, including his cell phone.

Summary of Case Context & HoldingIn this case the Defendant witnessed a fight between two individuals where one individual shot and killed the other. The killer then turned and pointed the gun at the Defendant. Defendant shot and fatally wounded the killer before the killer could fire again. At trial, the Defendant was charged with first degree murder and claimed self defense. The parties agreed that the jury would receive the standard or "pattern" jury instruction on self defense. But the trial court omitted a portion of the instruction and the Defendant was convicted. The omitted portion explained that "a person confronted with deadly force has no duty to retreat but can stand his ground" if that person was not the aggressor and was in a place where they have the lawful right to be. The court of appeals affirmed the Defendant's conviction, finding that "any place where [the defendant] has the lawful right to be" did not include the public street where the altercation occurred. The Supreme Court overturned that holding, finding that the instruction should have been given. The Supreme Court held that there was a reasonable possibility that a different result would have been reached at trial if the proper instruction was given. As a result, the Supreme Court held that the omission of "No Duty to Retreat" language from a jury instruction warranted a new trial for a criminal homicide defendant.

Summary of Case Context & HoldingThe Supreme Court held that the trial court did not err in suppressing the custodial statement of Defendant juvenile, who was 15 years old at the time of his statement, since he did not knowingly and intelligently waive his rights before speaking with investigators while in police custody because a video recording reflected that Defendant never once expressed any affirmative understanding of his rights or a desire to waive them. Further, Defendant, who had been at the police station for approximately 10 hours, was extremely distraught and appeared to have had minimal capacity to understand what little the investigators attempted to communicate regarding his rights. Defendant did not sign the waiver form, or even look at it, and engaged in no discussion with the officers or his mother, regarding his rights. The Supreme Court explained that whether a juvenile has knowingly and intelligently waived his constitutional rights “depends on the totality of the circumstances surrounding [the] police interrogation.” Among the factors to be considered are the accused's age and education; his knowledge of the charge and his constitutional rights; his ability to consult with family, friends, or an attorney; the length, method, and time of the interrogation; and whether he previously refused to give a statement or repudiated the statement later. The State bears a heavy burden in establishing a juvenile's knowing and intelligent waiver of rights. While Defendant's mother indicated that she understood her son's rights, her understanding is of little consequence given that Defendant could not rely on his mother to waive his rights. The Supreme Court affirmed the trial court's order ruling that the statement was inadmissible at trial.

Summary of Case Context & HoldingThe Supreme Court held that the absence of a procedural rule did not limit the court of appeals' jurisdiction or discretionary authority to issue writs of certiorari. In this case the Defendant pled guilty to driving while impaired after the trial court denied Defendant's motion to dismiss. Defendant retained the right to appeal the motion to dismiss under her plea agreement. The Defendant appealed and petitioned for writ of certiorari. The court of appeals denied Defendant's certiorari petition because the court claimed it lacked a procedural mechanism to issue the writ without invoking its discretion under Rule 2 of the North Carolina Rules of Appellate Procedure. Rule 2 allows appellate courts in the state to suspend the requirements of the rules of appellate procedure, but the use of this rule is up to the discretion of the judge. The appellate judge declined to invoke their discretion to issue the writ of certiorari. Notably, the General Assembly of North Carolina has given courts of appeals jurisdiction to issue writs via a statute. Accordingly, when the Defendant appealed, the Supreme Court held that the court of appeals had jurisdiction to grant the writ, that lack of a specific procedural rule did not prevent the appellate court from granting the writ, and that the court of appeals could also exercise discretion under Rule 2 to issue the writ. The Supreme Court reasoned that the appellate court could not impose limits on its own jurisdiction and remanded the case for further proceedings.

Summary of Case Context & HoldingDefendant was charged with theft under § 45-6-301(1)(a), MCA. During closing argument, the prosecutor told the jury, "The presumption of innocence that you came into this trial with no longer exists at this point." Defense counsel did not object. Subsequently, the jury found Defendant guilty of felony theft and he was sentenced to ten years in prison. On appeal, Defendant argued that the prosecutor's statement regarding the presumption of innocence constitutes plain error requiring reversal and remand for a new trial. Concluding that the prosecutor's statements could cause a reasonable juror to question the language of the preliminary jury instruction and, therefore, have the potential effect of removing the presumption of innocence from the Defendant, the Court determined that the prosecutor's comments required reversal of the defendant conviction.

Summary of Case Context & HoldingDefendant was convicted by jury of malice murder and other charges. The trial court granted a new trial based on evidentiary errors and ineffective assistance of counsel. The errors of trial counsel included: (1) failure to cross-examine the detective with evidence that he testified falsely about witness's statements to him which amounted to deficient performance; (2) failure to object to hearsay and bolstering testimony by the detective which amounted to deficient performance; and (3) a combined prejudicial effect of improper admission of hearsay testimony and the trial counsel's deficient performance. The State appealed, arguing that none of the claimed errors by counsel or the trial court resulted in sufficient prejudice or harm to require reversal. Due to the large number of errors at issue, the Supreme Court held that courts considering whether Defendant is entitled to a new trial should consider collectively prejudicial effect of trial court errors and any deficient performance by counsel. This holding overruled prior precedent that precluded full consideration of the cumulative effect of multiple errors at trial. The Supreme Court affirmed the grant of a new trial.

Summary of Case Context & HoldingDefendant was convicted of first-degree felony murder, attempted first-degree murder, first-degree burglary, and three counts of aggravated assault after a domestic violence incident. Defendant entered the house of his ex-girlfriend and mother of his children and began beating her. Defendant's four children and two from a pre-existing relationship fled, but defendant stabbed one of them several times, resulting in their death. Defendant then shot his ex-girlfriend in the head, but she survived. During trial, the court allowed testimony of an expert on domestic violence regarding the characteristics of a typical domestic abuser in instances of separation assault. Defendant was ultimately convicted and sentenced to death. On automatic appeal to the Supreme Court, the Court determined that the expert's testimony was improper profile evidence because it showed defendant possessed abstract characteristics typically displayed by persons engaged in the same kind of activity, which may have led the jury to convict him "not for what he did but for what others are doing." The Court opined that, while profile evidence may be proper in the context of suppression or probable cause hearings, it cannot be used as substantive proof of guilt. The Court then went on to decide that admitting improper profile evidence was not harmless error, and reversed Defendant's convictions for first-degree murder and first-degree burglary, remanding for a new trial on those counts. The Court affirmed the remaining convictions.

Summary of Case Context & HoldingPursuant to Ariz. Rev. Stat. 13-753(K)(3), a finding that a defendant has an intellectual disability requires a mental deficit "existing concurrently with significant impairment in adaptive behavior" before the defendant is eighteen. At issue in this case was the impact of Moore v. Texas, 581 U.S. 1 (2017) and Moore v. Texas, 139 S.Ct. 666 (2019) on Section 13-753(K)(1)'s definition of "adaptive behavior[,]" which requires the legal determination of intellectual disability to be informed by the views of the medical community. The Arizona Supreme Court held that the holdings of those cases did not eliminate section 13-753(K)(1)'s requirements that the trial court conduct an overall assessment to determine if the defendant has a deficit in any life-skill category and, if a deficit exists, determine whether it affects the defendant's ability to meet "the standards of personal independence and social responsibility expected of defendant's age and cultural group." Because the trial court did not conduct an overall assessment of Defendant's ability to meet society's expectations of him, the Supreme Court reversed and remanded the case for a new intellectual disability determination.

Summary of Case Context & HoldingDefendant appealed his sentence that re-sentenced him to life without parole for three counts of deliberate homicide committed when he was a juvenile, arguing it as unconstitutional in light of the U.S. Supreme Court decisions in Miller v. Alabama, 567 U.S. 460 (2012) and Montgomery v. Louisiana, 577 U.S. 190 (2016), which held that mandatory sentences of life without parole for juvenile offenders are unconstitutional "for all but the rarest of children, those whose crimes reflect 'irreparable corruption.'" The Court held that Defendant was not entitled to his own team of experts to assist in his defense before resentencing because, while he was indigent, and his youthful mental condition was relevant to determining whether he was "irreparably corrupt" and "permanently incorrigible," his sanity had never been at issue—either at his original trial and sentencing or at resentencing. The Court determined that Defendant does not have a constitutional right to a psychiatrist to aid in his defense when his sanity was not at issue. The Court also held that the district court erred when it found that Defendant was "irreparably corrupt" and "permanently incorrigible" after the sentencing hearing because the Court failed to consider the Miller factors, including undisputed evidence of rehabilitation progress over 33 years of incarceration. The Court found that post-offense evidence of rehabilitation is clearly required to be considered by a court resentencing a juvenile who is serving a sentence of life without parole. Defendant was therefore entitled to a new resentencing hearing. The Court also found that a jury is not required to determine irreparable corruption and permanent incorrigibility—that determination is properly left to the resentencing judge.

Summary of Case Context & HoldingA bartender was charged with selling beer to an underage informant. The applicable statute the Defendant was charged under defined beer as "containing one-half one percent or more . . . of alcohol." The judge declined to allow a report on the beer's contents and instead took judicial notice that the beer was an intoxicated liquor, which resulted in the jury finding the Defendant guilty. On appeal, the Ninth Circuit reversed the conviction holding that the trial court should not have taken judicial notice of an element of a crime or a fact that was not generally known. The case was thereafter remanded to the trial court and the Defendant thereafter argued that retrial was barred by his Fifth Amendment rights prohibiting double jeopardy because the appellate court's reversal was based on an insufficiency of evidence (rather than just an error that occurred at trial). The Supreme Court agreed and held that when the trial court’s improper judicial notice is the sole evidence that proves the State’s case, double jeopardy bars a retrial.

Summary of Case Context & HoldingDefendant Terry Jones was convicted of two counts of sexual assault and two counts of criminal sexual misconduct. The charges were based on allegations that Defendant raped on two occasions a nineteen-year-old girl who was living with him and his family. The appeal involved a petition for post-conviction relief (PCR), in which the Defendant claims defense counsel was ineffective for failing to (1) procure the appearance of an alibi witness who would have provided exculpatory and corroborative evidence that would have supported his defense; (2) obtain and introduce into evidence phone records that would have corroborated the defense's theory of why the accuser fabricated the sexual assault charges against him; and (3) advise Defendant that, if he were to testify, the jury could be informed only that he has a prior conviction for a "fourth-degree crime" and not a conviction for endangering the welfare of a child. The PCR court denied Defendant's petition without conducting an evidentiary hearing and the Appellate Division affirmed. The superior court granted certification solely to consider Defendant's assertion that his claims of ineffective assistance of counsel deserved an evidentiary hearing. The Supreme Court held that the post-conviction relief court should have resolved the disputed facts involved in Defendant's ineffective assistance of counsel claim only after an evidentiary hearing had been conducted.

Summary of Case Context & HoldingTwo deputies (Jake Lancaster and Jonathan Cooper) pulled over a woman for failing to use a turn signal. The woman had been driving to visit a friend, Thomas Jones, and was pulled over on the street in front of Jones’s home. Jones stood on his property and observed the scene with a flashlight pointed towards the officers. Jones briefly asked Lancaster some questions, and his interaction was calm and respectful. Jones took a few steps backwards and continued to observe the scene, during which Lancaster told Jones to go back towards his house, or be arrested for interfering. Jones did not move. Seconds later, both deputies rushed towards Jones, tased him, handcuffed him, and arrested him. During the altercation Jones lost consciousness. Jones was later convicted of interfering with a law enforcement officer and sentenced to 30 days in jail and a fine. Jones appealed the conviction, asserting that the ordinance under which he was convicted (stating it is unlawful for any person to interfere with any law enforcement officer in the discharge of their duty) was unconstitutionally overbroad and void for vagueness, and that it was unconstitutional as applied to his conduct. The Supreme Court declined to rule on the broader constitutional validity of the ordinance, but held that the ordinance had been improperly applied to Jones and reversed his conviction. The Supreme Court stated that the officers had grossly abused their discretion in this context, and that Jones had done nothing more than observe and ask questions of the officers, both of which are constitutionally protected conduct.

Summary of Case Context & HoldingTimothy Ray Jones Jr. admitted to killing his five children through strangulation and later leaving their bodies in a remote area to decompose. He entered a plea of not guilty by reason of insanity (NGRI). The jury rejected his insanity defense, returned five guilty verdicts, and the trial court adopted the jury’s recommendation of a death sentence. Jones raised eight issues on appeal (two related to juror qualification, one related to voir dire and jury instruction, and five related to the admission of evidence): (1) Jones alleged that one juror had been erroneously qualified because that juror would only consider mitigation evidence within a recent timetable, but the Supreme Court upheld that juror’s qualification, explaining that the juror repeatedly stressed throughout voir dire the importance of facts and evidence; (2) Jones alleged another juror, who had expressed confusion about whether she could meaningfully consider a NGRI verdict, had been erroneously disqualified. The Supreme Court disagreed, and upheld her disqualification because her responses during voir dire indicated she could not consider a NGRI verdict unless she was informed of its consequences, and the trial court is forbidden from informing the jury of those consequences; (3) Jones alleged the trial court erred in denying his request for voir dire and a jury instruction detailing the consequences of a NGRI verdict. The Supreme Court affirmed the trial court’s actions, holding that an instruction is improper in a capital trial (which is uniquely bifurcated), because NGRI is a verdict during the guilt phase, not the sentencing phase, and also because if an NGRI verdict is rendered, the jury has no sentencing responsibilities; (4) Jones argued that the trial court erred in denying his motion to suppress evidence obtained when he was stopped at a safety checkpoint on the road, asserting that the checkpoint was unconstitutional because its primary purpose was general crime prevention. The Supreme Court disagreed, explaining that the primary purpose of the checkpoint was highway safety, not general crime prevention, that the policy required all vehicles be stopped at the checkpoint, and that the stops were brief and minimally intrusive; (5) Jones argued that the trial court improperly excluded expert testimony that would have challenged the State’s expert testimony alleging that Jones had exaggerated his mental illness symptoms. The Supreme Court agreed that the exclusion was error and that the probative value of admitting the expert’s testimony was not substantially outweighed by the risk of unfair prejudice to the State. However, the State ultimately found the error to be harmless because Jones had seven other expert witnesses testify in support of his NGRI defense, and the additional expert testimony would not have likely affected the jury’s decision to impose a death sentence; (6) Jones alleged that mitigation evidence pertaining to his future dangerousness, remorse, and social history had been improperly excluded. The Supreme Court disagreed, holding that the evidence regarding his future dangerousness was irrelevant, that excluding evidence regarding his remorse was harmless, and that excluding evidence regarding certain family events before Jones’s birth was irrelevant to Jones’s character; (7) Jones alleged that the trial court improperly excluded testimony from his mother meant to serve as mitigation evidence of Jones’s state of mind and mental illness. The Supreme Court upheld the exclusion, concluding that Jones's mother’s testimony had no probative value and risked confusing the issue of Jones’s mental state with the issue demonstrated by the testimony (his mother’s mental state); and (8) Jones argued that the admission of ten gruesome autopsy photos was unfairly prejudicial. The Supreme Court agreed, concluding that their admission had no probative value and was substantially outweighed by danger of unfair prejudice to Jones. However, weighing the horrific facts of the case against the improper admission of the photographs, the Supreme Court found that the error was harmless and the photos did not contribute to the jury’s death sentence. Finally, the Supreme Court conducted mandatory proportionality review. Emphasizing the horrific facts of the case, the Supreme Court upheld the death sentence, finding it to be neither excessive nor disproportionate.

Summary of Case Context & HoldingThe Supreme Court considered whether under Rule 404 (b), O.C.G.A. § 24-4-404(b), of the new Georgia Evidence Code, evidence of Defendant's 2005 conviction for a DUI was admissible in a subsequent prosecution for driving under the influence. The Supreme Court found that evidence of Defendant's prior conviction was admissible pursuant to Rule 404(b) and that the trial court did not abuse its discretion in admitting the evidence because it was relevant for the limited purpose of establishing Defendant's intent and knowledge in the charged DUI crimes. Rule 404 (b) is, on its face, an evidentiary rule of inclusion which contains a non-exhaustive list of purposes other than bad character for which other acts evidence is deemed relevant and may be properly offered into evidence. The Supreme Court held that other acts evidence may be relevant under Rule 404 (b) without regard to whether the charged crime is one requiring a specific or general intent, when it is offered for the permissible purpose of showing a criminal defendant's intent and knowledge.

Summary of Case Context & HoldingDefendant Rodney Christopher Jones was charged with possession of hashish, a form a cannabis resin. Defendant is a registered qualifying patient under that the Arizona Medical Marijuana Act (AMMA), which allows him to carry and use medical marijuana for medical treatment. Defendant moved to dismiss the charges, arguing his use was allowed under AMMA. The State argued that the AMMA only provides a defense for the use of a marijuana from which the resin has not been extracted and does not apply to resin or its extracts. Agreeing with the State, the trial court denied Jones' motion. The court of appeals affirmed Jones' convictions in a divided opinion, holding that the AMMA did not immunize his possession of hashish. The Arizona Supreme Court reversed Jones' conviction because the definition of marijuana in Ariz. Rev. Stat. § 36-2801(8) includes resin, and by extension hashish, and Ariz. Rev. Stat. § 36-2811(B)(1) immunizes the use of such marijuana consistent with the AMMA.

Summary of Case Context & HoldingThe Defendants were convicted of manslaughter and child abuse and appealed. On appeal, the appellate court reversed the trial court's decision holding that an appellate court can reverse a sentence based on its own finding that the record does not support the sentence. The Supreme Court rejected the appellate court's attempt to revisit a sentence based on its disagreement with the trial court's analysis and held that the appellate court could not weigh the evidence in the record and substitute its judgment for that of the trial court. Further, although the appellate court said that the record did not support the trial court's sentence, that did not mean that the trial court's sentence was “otherwise contrary to law” (thus, the appellate court still could not modify it).

Summary of Case Context & HoldingIn this case the State, on the evening of trial, disclosed to Defendant that it planned to use more than 800 recorded calls made by Defendant from jail. The trial court denied the Defendant's motion to continue following this disclosure. The Supreme Court held that the trial court committed constitutional error in denying Defendant's motion because the time afforded to the Defendant's attorney to prepare was inadequate to satisfy the Defendant's right to effective assistance of counsel and to confront witnesses against him. However, the Supreme Court affirmed the Defendant's felony murder conviction on the grounds that the error was harmless beyond a reasonable doubt for that conviction. The Supreme Court reached this conclusion because the calls introduced were rebuttal evidence for the State against the testimony of the Defendant's expert witness. The matters testified to by the Defendant were irrelevant, as a matter of law, to the felony murder charge. Accordingly, the Supreme Court reasoned that the trial courts error in denying Defendant's counsel time to review the calls was harmless beyond a reasonable doubt as to the Defendant's felony murder conviction. A new trial was ordered for the Defendant's conviction for robbery with a dangerous weapon because the expert testimony was relevant to the robbery charge.

Summary of Case Context & HoldingThe Supreme Court held that an officer did not unconstitutionally extend a traffic stop by searching Defendant's car without a warrant after discovering that the Defendant had a criminal history. The officer had testified that the Defendant was stopped late at night, in a high-crime area, appeared nervous, and attempted to hinder the officer's view of the vehicle's center console. Given the testimony provided by the officer, the Supreme Court determined that the officer's suspicion that the Defendant might be armed and dangerous was reasonable under the circumstances. As a result the warrantless search was permissible.

Summary of Case Context & HoldingThis case arose from sexual contact between a 17-year-old Defendant and an 11-year-old autistic girl. The district court denied Defendant's request to transfer the case to youth court based on the "serious and troubling" nature of the offense. The district court may only transfer a case to youth court if it finds, by a preponderance of the evidence, that: (a) a youth court proceeding and disposition will serve the interests of community protection; (b) the nature of the offense does not warrant prosecution in the district court; and (c) it would be in the best interests of the youth if the matter was prosecuted in youth court (Section 41-5-206(3)(b), MCA). Because the Legislature has designated those offenders charged with certain specific serious crimes be first treated as adults, a major consideration under Montana precedent for transferring a case from adult court to youth court is the extent to which the offense reflects the offender's youthfulness. The Court found that an offender's youthfulness, social maturity, impulsivity, brain development, and other measures of maturity are an important consideration in a transfer decision. The Court held that the district court not only made a mistake but misapprehended the evidence presented by defendant suggesting that the nature of the offense did not warrant district court prosecution, instead reaching its conclusion based purely on the egregious nature of the offense, and by doing so the district court abused its discretion.

Summary of Case Context & HoldingDefendant entered a massage parlor, struggled with the owner, and ultimately bound and fatally stabbed her. He was charged with first-degree murder, kidnapping, and burglary, with the State seeking the death penalty based on multiple aggravating circumstances. Defendant was convicted and sentenced to death, resulting in an automatic appeal to the Arizona Supreme Court, which affirmed the conviction. Defendant first challenged Arizona’s sentencing scheme as unconstitutional, but the Court found this issue settled in Hidalgo v. Arizona, 390 P.3d 783 (Ariz. 2017), and rejected his request for a hearing. He also argued that the "heinous, cruel, or depraved" aggravating factor was unconstitutionally vague, but the Court upheld it, citing detailed jury instructions and sufficient evidence. The Court further found no error in the State’s closing arguments regarding that factor. Defendant contended that the "ineligible for parole" jury instruction was misleading, but the Court deemed it accurate in explaining potential executive clemency after 25 years. The Court found two harmless errors: one in the limited jury instruction on mental impairment and another in testimony about prison conditions linked to a plea offer. It upheld instructions on mercy and sympathy and found no abuse of discretion in limiting irrelevant or duplicative mitigating evidence. The Court ruled the disclosure of redacted defense interview notes and the compulsion of signed releases for difficult-to-obtain records was proper. Defendant’s claims of improper limits on voir dire and jury strikes were rejected, as were objections to the admission of a full expert report. The Court also dismissed claims of prosecutorial misconduct, including misstatements of law, vouching, evidence suppression, burden-shifting, and inflammatory tactics. The Court upheld the denial of a motion to change counsel, noting Defendant repeatedly acknowledged the adequacy of representation. The Court concluded that the jury acted within its discretion in finding aggravating factors outweighed mitigation and affirmed the death sentence.

Summary of Case Context & HoldingDefendant appealed from a criminal conviction in the district court arguing that the court abused its discretion by denying his request for substitution of counsel. The Court noted that a defendant may not demand substitute counsel simply because he lacks confidence in or does not approve of his counsel and a defendant is not entitled to counsel of his choice. Further, a defendant is not entitled to substitute counsel based on a general claim of ineffective assistance of counsel. To the contrary, to obtain substitute counsel, the defendant must present material facts establishing: (1) a complete collapse of the attorney-client relationship; (2) a total lack of communication between defendant and counsel; or (3) ineffective assistance of counsel. A defendant's constitutional right to substitute counsel arises when a defendant can present material facts showing that the attorney-client relationship has deteriorated to the point where the irreconcilable conflict or breakdown in communication prevents the mounting of an adequate defense. The Court used this case as an opportunity to enunciate a clearer standard for substitution of counsel, holding that a defendant could seek substitution based on a claim of ineffective assistance of counsel, but instead of looking to legal strategy or trial tactics of counsel, the trial court was required to focus on an alleged conflict in interest, a conflict between the defendant and counsel, or a breakdown in communication that prevented the mounting of an adequate defense. In Defendant's case, the Court found that the district court performed an adequate initial inquiry because it critically analyzed Defendant's factual allegations (that counsel did not file certain pretrial motions, did not interview any witnesses, and changed his phone number to prevent Defendant from contacting him) as well as counsel's specific explanations addressing those complaints (counsel considered the motions frivolous, did interview the two witnesses, and did not change his phone number). Accordingly, the Court concluded that the district court did not abuse its discretion in determining Defendant did not present a seemingly substantial complaint for ineffective assistance of counsel. The Court affirmed Defendant's conviction.

Summary of Case Context & HoldingA detective received information from several informants that the Defendant had recently sold drugs and would soon travel to Chicago to transport more drugs in a van. A U.S. Supreme Court decision held that attaching GPS tracking device to a vehicle is a search under the Fourth Amendment. However, relying on his understanding that a search warrant was not required, the detective attached a GPS tracking device to the Defendant's van without obtaining a warrant. The GPS led the police officer to the van and another Defendant's car where ultimately the officers found the cocaine. The Supreme Court held that attaching a GPS tracking device to the Defendant's vehicle was admissible evidence because the officers acted objectively reasonably and in good faith, believing these actions were lawful, noting that new developments in U.S. Supreme Court jurisprudence could not have been anticipated by a reasonable officer.

Summary of Case Context & HoldingDefendant was arrested for various drug offenses, and later fled New Jersey. A bench warrant was issued for his arrest and Defendant was arrested and charged with other offenses in New York State. Defendant remained in custody on the New York charges through sentencing on the New Jersey charges. The State sought an interstate detainer with New York, but the Defendant was not transferred to New Jersey until he was sentenced on the New York charges. Defendant pled guilty to the New Jersey charges, and then sought jail credit for the time he spent in pre-sentence custody in New York. The sentencing judge denied Defendant's request. On appeal, the Appellate Division awarded Defendant credit from the date the interstate detainer was filed. The State sought certification and the Supreme Court remanded the case to the Appellate Division for reconsideration. The Appellate Division reaffirmed its decision. On appeal, the New Jersey Supreme Court reversed and reinstated the trial court's sentence. The Supreme Court held that defendants who are confined in another state on non-New Jersey criminal charges are not entitled to jail credit for time spent in pre-sentence custody against any sentence imposed on their New Jersey charges. The Court explained that by limiting jail credit to defendants who are either detained out of state exclusively on New Jersey charges or who are confined in New Jersey provides uniformity to the administration of the criminal justice system.

Summary of Case Context & HoldingJerome Jenkins and two others robbed a convenience store, shooting and killing the store clerk, and injuring another worker. The same trio robbed two other convenience stores three weeks after the first robbery, killing another store clerk. Jenkins was convicted of murder, attempted murder, and armed robbery, and sentenced to death by a jury based on the murder charge. The Supreme Court reviewed seven errors Jenkins alleged the trial court made and conducted mandatory review of the death sentence. First, Jenkins alleged that the trial court denied him the right to plead guilty and be sentenced by a jury, since he was sentenced by the court. During a pre-trial hearing, the court made an inaccurate statement of law to Jenkins regarding whether he would receive the death penalty if he plead guilty. Although this was an error by the trial court, the Supreme Court found the issue was not preserved for review. Second, Jenkins alleged the trial court erred in refusing to admit as evidence an expert statement showing Jenkins had killed the store clerk because he was told to do so by his accomplice, since the trial court found the statement to be hearsay and excludable under the South Carolina Rules of Evidence. See SCRE 703. The Supreme Court ultimately found that the exclusion of expert testimony on hearsay grounds was not an abuse of discretion by the trial court, as the trial court's analysis, while a close question in terms of hearsay applicability, was ultimately within the range of a reasonable interpretation of the hearsay doctrine and SCRE 703, and did not thus consist of an abuse of discretion by the trial court. Third, the trial court did not allow Jenkins’s counsel to tell the jury that a life verdict does not have to be unanimous. The Supreme Court agreed with this action, reasoning that the State has a legitimate interest in fostering resolution of criminal trials by verdict and informing jurors that an individual juror can control the outcome of the trial by holding out their vote frustrates the goal of a unanimous jury verdict. The fourth and fifth errors are Jenkins’s appeal of the trial court’s qualification of two jurors. One juror stated she would not sentence someone to death just because she wanted to, and that the decision should be based on facts and evidence. The Supreme Court found that nothing in her response would have prevented or substantially impaired the performance of her duties as a juror. Although another juror used to work as a detention officer at the region’s police department and had prior knowledge of Jenkins’s case, he assured the trial court he would decide the case based on evidence presented at Jenkins’s trial, which the Supreme Court agreed satisfied the qualification requirements. Sixth, Jenkins alleged that the admission of evidence that he had had 26 pre-trial disciplinary infractions while held in the South Carolina Department of Corrections was unconstitutional and unfair of the State to use his own conduct against him. The Supreme Court disagreed, stating that evidence of misconduct as a pre-trial detainee was relevant to determining Jenkins’s future dangerousness as an aggravating circumstance in the sentencing phase of the trial. Seventh, Jenkins argued that the trial court should have admitted evidence regarding a 2018 prison riot that occurred at Lee Correctional Institution while he was housed there, stating that he acted in an unruly manner because he lived in an unruly environment. The Supreme Court disagreed, stating that Jenkins’s nonparticipation in the riot had no relevance to his sentencing. Finally, the Supreme Court conducted mandatory review of Jenkin’s death sentence, and found that the death penalty here was neither excessive nor disproportionate to the sentences imposed in similar capital cases, and upheld the sentencing.

Summary of Case Context & HoldingIn 2015, four defendants were charged with attempted murder, aggravated battery, kidnapping, and violations of the Georgia Street Gang Terrorism and Prevention Act. The State gave notice of its intention to introduce into evidence at trial four certified copies of convictions relating to various gang members pursuant to O.C.G.A. § 16-15-9. The Defendants filed a “Motion in Limine to Declare O.C.G.A. § 16-15-9 Unconstitutional and to Bar the Introduction of Third Party Convictions,” arguing that the statute on its face violated the Confrontation Clause of the U.S. Constitution. The trial court entered an order finding that the admission of the third party convictions and the prior conviction of one of the defendants during the trial would violate their Sixth Amendment rights to confront the witnesses against them. The trial court granted the motion to declare the statute unconstitutional, and excluded the use of any of the third party convictions. The State appealed, but the Supreme Court concluded the trial court correctly determined that OCGA § 16-15-9 was unconstitutional on its face to the extent that it authorized the admission of the convictions of non-testifying non-parties as evidence of a criminal street gang.

Summary of Case Context & HoldingDefendant was a passenger of a truck that he sometimes drove while accompanied by its owner. Police officers collected information over several days from a GPS tracking device they had placed on the truck without obtaining a warrant. The trial court denied Defendant's motion to suppress, reasoning that Defendant, as a passenger, did not have standing to object to the State’s use of the GPS tracking device on a commercially-owned truck. The court of appeals affirmed. Defendant challenged the decision on the grounds that U.S. Supreme Court precedent, United States v. Jones, 565 U.S. 400 (2012), recognized that a government trespass may constitute a search. However, the Supreme Court of Arizona rejected the application to Defendant's case because the opinion did not alter the settled principle that a person can only challenge a search if it invades his or her own Fourth Amendment rights. The Supreme Court held that (1) Defendant lacked standing to challenge, under the theory of trespass, that the GPS monitoring of a commercial truck he drove was an illegal search in violation of the Fourth Amendment; and (2) the good-faith exception to the rule applied to allow for admission of evidence of drugs discovered as a result of the officers warrantless placement and monitoring of a GPS tracking device on a commercial truck that Defendant drove.

Summary of Case Context & HoldingJLG, the Defendant, was charged with, among other things, sexually abusing Bonnie, who initially did not report the abuse because the Defendant had held a gun to her head and threatened to hurt her, her mother, and her brother if she told anyone. At trial, the Defendant argued that Bonnie’s delay in reporting her allegations made her less credible. The trial court admitted expert testimony about Child Sexual Abuse Accommodation Syndrome (CSAAS) to educate the jurors about potentially counterintuitive behaviors that are sometimes exhibited by child sexual-abuse victims, such as delays in reporting the abuse. At the Appellate Division, the Defendant filed a petition for certification of the issue of whether his motion to exclude testimony of expert witness on child sexual abuse accommodation syndrome was properly denied. The ACLU-NJ, as friend-of-the-court, argued that because CSAAS is not scientific, admitting expert CSAAS testimony violates a defendant's right to Due Process. The Supreme Court ultimately held that CSAAS testimony was insufficiently reliable to be admissible at trial because (i) whether a child-abuse victim's delayed disclosure is beyond the understanding of the average juror, such that expert testimony may be needed, will depend on the facts of the case; and (ii) no juror needed help from an expert to evaluate why child delayed disclosure of sexual abuse. The Court however still convicted the Defendant because the evidence against the Defendant was so overwhelming that the admission of the CSAAS testimony was harmless.

Summary of Case Context & HoldingThe Defendant in the case was charged with operating a motor vehicle while under the influence of an intoxicant and filed a motion to suppress. The Supreme Court held that discarding a cigarette butt onto a highway violates a littering statute; that the state legislature has authorized state troopers to investigate incidents of littering and arrest violators; and that the troopers had the authority and probable cause to investigate once they saw the Defendant disposing of his cigarette butt on the highway.

Summary of Case Context & HoldingAppellant, Damien Inman, was convicted and sentenced to life without the possibility of parole for the robbery, kidnapping, and murder of a woman. Appellant challenged his conviction on several bases, with the Court reviewing a claim that the circuit court improperly granted the State’s Batson v. Kentucky, 476 U.S. 79 (1986) challenge to preserve the selection of a juror notwithstanding a race-neutral explanation for striking the juror offered by Appellant. In the original trial, Appellant’s counsel moved to strike a juror because the juror was a farmer, and likely unequipped to understand the forensic evidence that would be presented in the case. The State made a Batson challenge in response, challenging the strike and asserting that Appellant’s striking of the juror was racially motivated, in violation of the Fourteenth Amendment. For a Batson challenge to succeed, three elements must be met: (i) the moving party must make a prima facie showing that the challenge was based on race; (ii) the opposing party must then offer a race neutral explanation for the challenge; and (iii) if the trial court finds that the burden under (ii) has been met, the trial court must determine whether the moving party has proved purposeful discrimination (including the use of a pretextual challenge). Here, the Court found that the circuit court made an error of law by placing the burden to disprove purposeful discrimination on the Appellant, instead of requiring the State to prove purposeful discrimination. Appellant offered a race-neutral explanation under prong (i), but instead of shifting the burden to the State under prong (iii), the circuit court itself rejected the explanation under (ii), which it was not entitled to do. After rejecting the explanation, the circuit court reinstated the juror, who ultimately became a part of the jury that convicted the Appellant. The Court reversed the circuit court’s ruling on the Batson challenge and remanded the case for a new trial.

Summary of Case Context & HoldingHyppolite, the Defendant, was charged with murder and weapons offenses based heavily on the statement of a single witness, Gregg, who identified Defendant as the shooter. Gregg gave his first statement shortly after the shooting, and said that he heard three to four shots but did not see the shooter. Some months later, he gave a second statement where he, among other things, identified the Defendant as the shooter. Defendant was eventually indicted, and the State subsequently disclosed additional materials. The materials disclosed revealed that the witness initially told the police he did not see the shooter. The witness had also identified two others he claimed were at the scene of the crime, but the newly disclosed statements contradicted him. Other evidence conflicted with the witness's version of events. The trial court correctly found that the additional discovery contained exculpatory evidence that should have been disclosed before the detention hearing. However, when the Defendant moved to reopen the pretrial detention hearing on this basis, the trial court denied the application, and the Appellate Division denied leave to appeal. The Supreme Court, however, disagreed with the lower court and granted leave to appeal. The Supreme Court ruled that (i) when exculpatory evidence is disclosed after a detention hearing, judges should use a modified materiality standard to decide whether to reopen the hearing, and if there is a reasonable possibility that the result of the detention hearing would have been different had the evidence been disclosed, the hearing should be reopened; and (ii) in this case, the belated disclosure of exculpatory evidence required reopening of the detention hearing. The Supreme Court clarified in its opinion that when the State seeks pretrial detention, the prosecutor must provide defense counsel with all exculpatory evidence no later than 24 hours before the hearing, and that a defendant can move to reopen a detention hearing anytime before trial. The Court also noted that the requirement to produce exculpatory evidence is grounded in the State’s affirmative obligation to disclose evidence favorable to a defendant.

Summary of Case Context & HoldingDuring a traffic stop, officers determined that the driver and backseat passenger had outstanding warrants. After the driver was placed in a police car, one of the officers addressed Defendant, who was in the front passenger seat. Defendant became agitated and the officer told him to get out of the car for a pat down. Once out of the car, Defendant reached into his waistband and shot at the officers, killing one of them. Defendant was convicted of first-degree murder of a law enforcement officer and attempted murder of a law enforcement officer and sentenced to death. The Court addressed a number of issues and held that (1) the trial court did not err in denying motion to exhume a victim’s cremated body to retrieve bullet fragments because even if the body had not been cremated, exhumation is reserved for extraordinary circumstances and the probative value of the bullet fragments, if there even were any, was speculative; (2) an evidentiary hearing was not required prior to denial of motion to dismiss for bad faith destruction of evidence due to the cremation because Defendant did not show bad faith on part of the police which was required given that evidence was only potentially useful; (3) the driver of the car was entitled to invoke her Fifth Amendment right to avoid being compelled to testify because she had reasonable grounds to fear prosecution based on testimony; (4) striking a juror for cause was warranted based on his views on the death penalty because their questionnaire clearly said they would not be able to render a death sentence and subsequent uncertainty was not enough to make their position unclear; and (5) the trial court erred in precluding Defendant from informing the jury of his parole ineligibility and the error was not harmless because under Simmons v. South Carolina, 512 U.S. 154 (1994), Defendant’s dangerousness was clearly at issue and Defendant maintained his objections to prohibitions on addressing it throughout the penalty phase. On the Simmons issue, the Court found that the trial court erred because it repeatedly denied Defendant’s request to address his ineligibility for parole when his dangerousness was clearly at issue because the State repeatedly referenced matters such as violent behavior toward other inmates and overall violent behavior. The Court determined that Defendant was entitled to a new penalty phase due to the error.

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

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

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

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

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

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

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

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

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

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