Articles Posted in Civil Rights

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The Supreme Court held that the court of appeals erred in reversing the trial court’s denial of Defendant’s motion to suppress, holding that the suppression motion contained sufficient findings of fact to support the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights pursuant to N.C. Gen. Stat. 7B-2101 before making certain incriminating statements. The court of appeals determined that the totality of the circumstances set forth in the record did not fully support the trial court’s conclusion that Defendant knowingly, willingly, and understandingly waived his juvenile rights. The Supreme Court reversed, holding (1) the trial court’s findings of fact had adequate evidentiary support, and those findings supported the trial court’s conclusion that Defendant knowingly and voluntarily waived his juvenile rights; and (2) in reaching a contrary conclusion, the court of appeals failed to focus upon the sufficiency of the evidence to support the trial court’s findings of fact and to give proper deference to those findings. View "State v. Saldierna" on Justia Law

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The Supreme Court held in this criminal case that while the claim asserted in Defendant’s motion for appropriate relief was not subject to the procedural bar established by N.C. Gen. Stat. 15A-1419(a)(3), the trial court did not err by denying Defendant’s motion for the reasons stated by the court of appeals. The jury returned a verdict convicting Defendant of first-degree murder, and the trial court sentenced Defendant to a term of life imprisonment without parole. Defendant later filed a motion for appropriate relief asserting, among other things, that his constitutional right to effective, conflict-free trial counsel had been violated. The trial court denied Defendant’s motion after conducting an evidentiary hearing. The Supreme Court concluded that Defendant’s ineffective assistance of counsel claim was not procedurally barred and overturned the trial court’s order denying Defendant’s motion for appropriate relief. The Supreme Court affirmed in part and reversed in part, holding (1) Defendant was not subject to the procedural bar created by N.C. Gen. Stat. 15A-1419(a)(3) with respect to his ineffective assistance of counsel claim; but (2) the trial court properly denied Defendant’s motion for appropriate relief. View "State v. Hyman" on Justia Law

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A police officer’s decision to briefly detain Defendant for questioning was supported by a reasonable suspicion of criminal activity. Defendant was indicted for robbery with a dangerous weapon. Defendant moved to suppress evidence obtained as a result of his seizure by the police officer, asserting that he had been unlawfully detained, in violation of his constitutional rights. The trial court denied the motion to suppress, and Defendant was subsequently convicted of common law robbery. The court of appeals ordered a new trial, concluding that the trial court committed prejudicial error by denying Defendant’s suppression motion and that the police officer lacked reasonable suspicion to detain Defendant for questioning. The Supreme Court reversed, holding that the undisputed facts established reasonable suspicion necessary to justify Defendant’s seizure. View "State v. Nicholson" on Justia Law

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The Supreme Court reversed the decision of the court of appeals in vacating the judgments entered by the trial court based upon Defendant’s convictions for first-degree murder and attempted first-degree murder on the grounds that certain evidence had been admitted in violation of the Confrontation Clause. The court of appeals concluded that the statements at issue were admitted in violation of Defendant’s constitutional right to confront the State’s witnesses against him. The Supreme Court reversed, holding that the trial court did not err by overruling Defendant’s confrontation-based objection and allowing the admission of the challenged evidence. View "State v. Miller" on Justia Law

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Defendant’s Fourth Amendment claims were not reviewable on direct appeal, even for plain error, because Defendant completely waived them. A police officer found cocaine in Defendant’s coat pocket during a traffic stop. Defendant did not move in liming to suppress evidence of the cocaine, nor did Defendant object to the State’s use of the cocaine evidence at any point during his trial. On appeal, Defendant argued that the trial court plainly erred by admitting evidence of the cocaine and that the seizure of the cocaine violated his rights under the Fourth Amendment. The court of appeals ordered a new trial, concluding that the trial court committed plain error by admitting evidence of the cocaine. The Supreme Court reversed, holding that Defendant waived his Fourth Amendment claims by not moving to suppress evidence of the cocaine before or after trial. The Court remanded the case for consideration of Defendant’s ineffective assistance of counsel claim because the court of appeals did not reach this claim. View "State v. Miller" on Justia Law

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The Supreme Court affirmed Defendant’s convictions for first-degree murder, sexual offense of a child by a adult offender, and other crimes and his sentence of death, holding that there was no error in Defendant’s trial or sentencing and that Defendant’s death sentence was not disproportionate to his crimes. Among other things, the Supreme Court held (1) Defendant failed to meet his burden under Strickland v. Washington, 466 U.S. 668 (1984), of establishing that he received ineffective assistance of counsel; (2) Defendant failed to identify any error in the trial court’s evidentiary rulings; (3) the trial judge did not abuse his discretion in denying Defendant’s motions for a mistrial based upon an improper remark by the prosecutor during closing arguments; (4) there was no error in the jury instructions; (5) Defendant received a capital sentencing proceeding free of prejudicial error; and (6) the death sentence was not excessive or disproportionate. View "State v. McNeill" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing an order denying Defendant’s motion to suppress and vacating Defendant’s guilty plea. Defendant moved to suppress the evidence derived from a search of the car he was driving after he was pulled over for traffic violations, arguing that the search violated the Fourth Amendment. The trial court denied the motion to suppress. The court of appeals reversed, concluding that the traffic stop had been unlawfully prolonged under the standard that the United States Supreme Court set out in Rodriguez v. United States, 575 U.S. __ (2015). The Supreme Court reversed, holding that the stop was not unlawfully prolonged under the standard set forth in Rodriguez. View "State v. Bullock" on Justia Law

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Defendant was subjected to a custodial interrogation as defined in Miranda v. Arizona, 384 U.S. 436 (1966), when police questioned him while he was confined under a civil commitment order, and therefore, the failure of police to advise him of his Miranda rights rendered inadmissible the incriminating statements he made during the interrogation. The trial court concluded otherwise and denied Defendant’s motion to suppress. Defendant was subsequently convicted of robbery with a dangerous weapon. The Supreme Court reversed the trial court’s denial of Defendant’s motion to suppress and vacated his conviction, holding that the trial court’s order denying Defendant’s motion to suppress was an erroneous application of the law and that the error was prejudicial. View "State v. Hammonds" on Justia Law

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In this criminal case, the prosecutor’s comments in his closing argument were improper but did not amount to prejudicial error in light of the evidence against Defendant, and therefore, the trial judge did not err by failing to intervene ex mero motu in the prosecutor’s closing arguments. The court of appeals vacated Defendant’s conviction and ordered a new trial, concluding that the prosecutor’s statements had the cumulative effect of resulting in unfair prejudice to Defendant, and therefore, the trial court erred by failing to intervene ex mero motu. The Supreme Court disagreed, holding (1) the prosecutor’s statements were improper; but (2) the statements were not so grossly improper as to prejudice Defendant’s due process rights. View "State v. Huey" on Justia Law

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N.C. Gen. Stat. 20-16.2(b) alone does not create a per se exception to the warrant requirement. At issue before the Supreme Court was whether section 20-16.2(b), which authorizes law enforcement to obtain a blood sample from an unconscious defendant who is suspected of driving while impaired without first obtaining a search warrant, was unconstitutionally applied to Defendant. Defendant in this case filed a pretrial motion to suppress testing performed by law enforcement on his seized blood. The trial court granted the motion, concluding as a matter of law that the seizure of Defendant’s blood was a search subject to Fourth Amendment protection and, under a totality of the circumstances test, no exigency justified a warrantless search. The court of appeals affirmed. The Supreme Court affirmed as modified, holding that section 20-16.2(b) is unconstitutional under the Fourth Amendment as applied to Defendant in this case because (1) there was no dispute that there were no exigent circumstances justifying a warrantless blood draw; (2) section 20-16.2(b) does not create a per se exception to the warrant requirement; and (3) the State did not carry its burden of proving voluntary consent. View "State v. Romano" on Justia Law