Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of sexual assault in the first degree and risk of injury to a child. The trial court sentenced Defendant to thirty-two years incarceration and lifetime sex offender registration. The appellate court affirmed. Defendant appealed, contending that the appellate court erred in finding that Defendant's objection to the admission of expert testimony was unpreserved. The Supreme Court affirmed, holding (1) the appellate court correctly found that defense counsel's objection was not preserved; and (2) therefore, the Court declined to review Defendant's claim that the State's expert improperly expressed an opinion on the ultimate issue. View "State v. Jorge P." on Justia Law

On a conditional plea of nolo contendere, Defendant was convicted of child pornography in the first degree. During the course of the proceedings, the trial court denied Defendant's motion to suppress numerous photographic and video recorded images depicting child pornography, which the police discovered in computer equipment that had been seized from Defendant's residence pursuant to a search warrant. Defendant appealed, claiming the trial court's denial of his motion to suppress was improper because the warrant authorizing the search of his residence was not supported by probable cause. The appellate court affirmed, concluding that the trial court properly determined the affidavit in support of the search warrant application contained sufficient facts to establish probable cause to believe that child pornography would be found at Defendant's residence. The Supreme Court affirmed, holding that the appellate court properly concluded probable cause existed to support the issuance of the warrant. View "State v. Shields" on Justia Law

After a jury trial, Defendant was convicted of manslaughter in the first degree and carrying a dangerous weapon. The appellate court affirmed. Defendant appealed, arguing, inter alia, that the trial court's instruction regarding Defendant's interest in the outcome of the trial in relation to the jury's credibility assessment of his testimony deprived him of his right to a fair trial. The Supreme Court affirmed, holding (1) the prosecutor did not commit prosecutorial improprieties that deprived Defendant of a fair trial; and (2) the trial court's instruction to the trial did not affect the fairness of the trial or prejudice Defendant. However, the Court directed trial courts in the future to refrain from instructing jurors, when a defendant testifies, that they may specifically consider the defendant's interest in the outcome of the case and the importance to him of the outcome of the trial. View "State v. Medrano" on Justia Law

Petitioner filed a petition for habeas corpus relief, arguing that his counsel provided ineffective assistance of counsel for failing to request an increase in bond on two prior charges so that Petitioner could be credited for presentence confinement credit on those charges. The habeas court granted relief, concluding that Petitioner had a Sixth Amendment right to the effective assistance of counsel for a matter pertaining to presentence confinement. The Supreme Court affirmed on the basis of its conclusion in Gonzalez v. Commissioner of Correction, decided this same day, holding (1) the habeas court properly determined that Petitioner was entitled to the effective assistance of counsel at the plea hearing and sentencing; and (2) the failure of Petitioner's counsel to request an increase in the bond on his first arrest constituted deficient performance and such performance prejudiced Petitioner by exposing him to an additional seventeen days in jail for which he received no credit. View "Huertas v. Comm'r of Corr." on Justia Law

Petitioner was arrested three times for three different offenses and later pleaded guilty to violation of a protective order and threatening in the second degree. Petitioner subsequently filed a second amended petition for a writ of habeas corpus, claiming that his counsel was ineffective for, among other things, failing to request that the court credit Petitioner with seventy-three days of presentence confinement credit for one of his first two arrests. The habeas court found that Petitioner met his burden of proving that counsel's performance was deficient and ordered the Commissioner of Correction to credit Petitioner with seventy-three days of presentence confinement credit. The appellate court affirmed, holding (1) Petitioner had a Sixth Amendment right to be represented by counsel at his arraignment; and (2) Petitioner was prejudiced by counsel's representation. The Supreme Court affirmed, holding that the appellate court properly ruled that (1) the Sixth Amendment confers a right to the effective assistance of counsel in matters pertaining to credit for presentence confinement; and (2) Petitioner showed deficient performance and prejudice within the meaning of Strickland v. Washington. View "Gonzalez v. Comm'r of Corr." on Justia Law

Petitioner entered guilty pleas, pursuant to the Alford doctrine, to three counts of burglary and one count of larceny and admitted a violation of probation. Petitioner subsequently filed a revised amended petition for a writ of habeas corpus alleging, inter alia, that trial counsel provided ineffective assistance. The habeas court granted the petition in part, concluding (1) counsel did not act in a constitutionally defective manner in her representation of Petitioner; but (2) counsel had an actual conflict of interest. The appellate court reversed, ruling (1) the habeas court misapplied the Rules of Professional Conduct in determining that counsel was burdened by an actual conflict of interest; and (2) the court improperly determined that a breach of the Rules alone was sufficient to establish a violation of the right to ineffective assistance of counsel. Finding no error, the Supreme Court affirmed. View "Anderson v. Comm'r of Corr." on Justia Law

After a jury trial, Defendant was convicted of murder. The Supreme Court affirmed, holding (1) any error in the trial court's curtailment defense counsel's cross-examination of a jailhouse informant regarding the maximum sentence the informant faced on pending felony charges at the time he incriminated Defendant was harmless; (2) any error in the trial court's decision to allow testimony from the informant that his parole officer supported his application for a sentence modification was harmless; (3) the trial court properly admitted into evidence testimony regarding Defendant's gang membership; and (4) the prosecutor engaged in prosecutorial impropriety during his cross-examination of Defendant's expert witness and during closing argument, but the improprieties did not deny Defendant of a fair trial. View "State v. Wilson" on Justia Law

After a court trial, Defendant was convicted in two separate cases of two counts of sexual assault in the first degree, five counts of risk of injury to a child, and one count of promoting a minor in an obscene performance. The Supreme Court affirmed, holding that the trial court (1) correctly found sufficient evidence to sustain Defendant's conviction for promoting a minor; (2) did not plainly err by admitting into evidence expert opinion evidence as to the fact that Defendant had physically, psychologically, and sexually abused the victim; and (3) did not err in permitting the state to present certain evidence of uncharged misconduct. View "State v. George A." on Justia Law

After a jury trial, Defendant was convicted of several crimes and sentenced to a term of imprisonment of fifty-five years for felony murder, twenty years for first degree robbery, and five years for carrying a pistol without a permit, each to run concurrently. Defendant subsequently filed a motion to correct an illegal sentence, claiming that felony murder was an unclassified felony subject to a maximum term of imprisonment of twenty-five years. The trial court denied the motion. The Supreme Court affirmed, holding that the trial court's sentence was proper because felony murder is not an unclassified felony but, rather, a felony classified as murder and, as such, is punishable by a term of imprisonment of twenty-five years to life. View "State v. Adams" on Justia Law

Claimant brought a claim before the Claims Commissioner seeking damages from the State as the coadministrator of the estate of her deceased daughter, who had died while confined in a correctional institution. In the course of Claimant's case, the Commissioner issued subpoenas to the Charlotte Hungerford Hospital requesting information about the decedent's treatment there. The Hospital refused to comply with the subpoena, arguing that the Commissioner had no authority to issue subpoenas to nonparties. The trial court enforced the Commissioner's subpoena, and the appellate court affirmed. Subsequently to the Supreme Court's certification of the Hospital's appeal, Claimant settled underlying case, and consequently, the State no longer sought to enforce the subpoenas. The Supreme Court dismissed the Hospital's appeal as moot and vacated the judgments of the lower courts, as the Court could no longer grant relief. View "State v. Charlotte Hungerford Hosp." on Justia Law