cases pt 2 Flashcards
nix v williams
Williams was convicted of murder. The U.S. Supreme Court reversed the conviction (in Brewer v. Williams) because police elicited from him the location of the victim’s body in violation of his Sixth Amendment rights. Williams was tried and convicted a second time. The victim’s body was entered into evidence at that trial. The government used the evidence because, regardless of the fact that Williams led police to the body, it would have inevitably been discovered by the search party that was looking for the body after the crime. On appeal, the state courts affirmed the conviction. On habeas petition, the Eighth Circuit Court of Appeals reversed, stating that the government had to prove an absence of police bad faith before the inevitable discovery rule could apply. The U.S. Supreme court reversed the Court of Appeals. It held that the inevitable discovery doctrine applies, and that the government need not prove an absence of bad faith.
horton v california
Petitioner moved to suppress evidence of an armed robbery that was discovered in plain view by an officer during execution of a search warrant. The officer expected to find those items, however, so the plain view discovery was not inadvertent. The trial court refused to suppress the evidence, and petitioner was convicted of armed robbery. The state appeals court affirmed the trial court’s decision on the motion to suppress. The state supreme court declined review. The U.S. Supreme Court affirmed. It held that a warrantless seizure of an item in plain view does not violate the Fourth Amendment, even though the discovery in plain view was not inadvertent.
whren v usa
Undercover officers observed Petitioners Whren and Brown in a truck. The driver of the truck (Brown) violated traffic laws by suddenly pulling away at an unreasonable speed. The officers stopped the truck and, upon approaching the truck on foot, saw plastic bags of crack cocaine in Whren’s hands. Petitioners were arrested. Prior to trial on drug charges, the District Court denied petitioners’ motion to suppress the drugs as discovered in violation of the Fourth Amendment. The Court of Appeals affirmed. The U.S. Supreme Court affirmed as well. The unanimous Court held that as long as there is probable cause to stop a vehicle for a traffic infraction, the subjective intent of the officer who stopped the car is irrelevant for Fourth Amendment purposes.
ny v belton
A police officer arrested four people in a speeding car. He examined passenger compartment, and found a jacket containing incriminating evidence. Issue. Whether “the constitutionally permissible scope of a search incident to his arrest include the passenger compartment of the automobile in which he was riding.”
Held. Yes. The court set out to firmly define the parameters of a search incident to arrest, established under previous law as “the area within the immediate control of the arrestee.” A reading of case law “suggests the generalization that articles inside the relatively narrow compass of the passenger compartment of an automobile are in fact generally, even if not inevitably, within ‘the area into which an arrestee might reach . . . a weapon” or evidence. Any containers within the passenger compartment could be searched for that same reason.
arizona v gant
Gant was pulled over and arrested for driving while license suspended. After being cuffed and secured in the back of a cop car, officers searched his car and found a gun and drugs. Gant moved to have the evidence suppressed as the result of an improper search. The Arizona court convicted Gant and he petitioned to the Supreme Court claiming the search violated his Fourth Amendment rights. Upon review, the United States Supreme Court held that the police may search a vehicle only if the arrested person is within reaching distance of the passenger compartment at the time of the search or reasonable belief that crime-related evidence is present in the vehicle exists.
Riley v california
Riley was convicted of a shooting related offense after evidence seized from his cell phone (incident to his arrest) was used against him in court. Riley filed a motion to suppress which was denied and later appealed to the state’s court of appeals claiming the search violated his Fourth Amendment rights. Riley, along with and similarly situated Wurie, petitioned the Supreme Court in a consolidated case. The Supreme Court held that the government may not conduct a warrantless search of a cell phone’s contents that was seized after an arrest absent any exigent circumstances.
us v carpenter
In April 2011, police arrested four men in connection with a series of armed robberies. One of the men confessed to the crimes and gave the FBI his cell phone number and the numbers of the other participants. The FBI used this information to apply for three orders from magistrate judges to obtain “transactional records” for each of the phone numbers, which the judges granted under the Stored Communications Act, 18 U.S.C. 2703(d). That Act provides that the government may require the disclosure of certain telecommunications records when “specific and articulable facts show[] that there are reasonable grounds to believe that the contents of a wire or electronic communication, or the records or other information sought, are relevant and material to an ongoing criminal investigation.” The transactional records obtained by the government include the date and time of calls, and the approximate location where calls began and ended based on their connections to cell towers—”cell site” location information (CSLI).
Based on the cell-site evidence, the government charged Timothy Carpenter with, among other offenses, aiding and abetting robbery that affected interstate commerce, in violation of the Hobbs Act, 18 U.S.C. 1951. Carpenter moved to suppress the government’s cell-site evidence on Fourth Amendment grounds, arguing that the FBI needed a warrant based on probable cause to obtain the records. The district court denied the motion to suppress, and the Sixth Circuit affirmed.
silverthorne lumber co vs usa
Silverthorne (the individual who owned the company) was cited for contempt for refusing to produce books and documents before the Grand Jury.
Silverthorne had been indicted and arrested. While Silverthorne (and his father) were detained, a U.S. Marshal “without a shadow of authority,” went to their company and seized all books and papers held there. The papers were seized pursuant to an invalid warrant, and a new warrant was drafted based on information in the documents seized. The Court ordered the original documents returned, and then issued a subpoena for the documents. The Silverthornes refused to produce the documents, arguing that the Court was benefiting from the original unlawful seizure, as without that seizure, they would not have been able to draft a new warrant for the materials.
ISSUE: Is it permissible for the government to benefit from an unlawful act? HOLDING: No.
us v wurie
wurie’s phone was seized and searched, evidence linked him to gang activity and shootings. Court held that the search needed a warrant, dismissing concerns about wiped evidence.
us v. Leon
Police officers executed a facially valid search warrant unveiling evidence that was later introduced at trial. The warrant was later determined to lack probable cause. Leon, along with others, moved to suppress the evidence claiming introduction of the evidence would violate their Fourth Amendment rights. The Court held that so long as the warrant was facially valid and the officers reasonable relied upon the warrant, the exclusionary rule does not apply because the police did not act improperly.
attorney rights
Gideon v. Wainwright (1963)
-selectively incorporated the right to an attorney in all felony matters
-overturned Betts v. Brady (1942)
Escobedo v. Illinois (1964) -right to an attorney was extended back in time so that it attached at the interrogation stage
Argersinger v. Hamlin (1972) -right to counsel applies any time there is a possibility of imprisonment.
Alabama v. Shelton (2002) -right to counsel applies to a defendant who was sentenced to a suspended sentence
Republican Party V. White
Minnesota’s Constitution provides for the selection of all state judges by popular election. The announcement clause of the Minnesota Supreme Court’s canon of judicial conduct prohibits a candidate from announcing his or her views on disputed legal or political issues. While running for associate justice of the Minnesota Supreme Court, Gregory Wersal filed suit, seeking a declaration that the announce clause violates the First Amendment and an injunction against its enforcement.
Wersal alleged that he was forced to refrain from announcing his views on disputed issues during the 1998 campaign, to the point where he declined response to questions put to him by the press and public, out of concern that he might run afoul of the announce clause. The District Court found that the announcement clause did not violate the First Amendment. The Court of Appeals affirmed.
Foster v. Chatman
In 1986, Timothy Tyrone Foster, an 18-year-old black man, was charged with murdering Queen White, an elderly white woman. At the trial, the prosecution used peremptory strikes against all four of the qualified black jurors. Pursuant to the Supreme Court’s decision in Batson v. Kentucky, which prohibits the use of peremptory strikes on the basis of race, the defense objected to those strikes, and the burden shifted to the prosecution to prove that there were race-neutral explanation for the strikes. The prosecution provided reasons, and the trial court held that the reasons were sufficient. An all-white jury convicted Foster of murder and imposed the death penalty.
Foster filed a motion for post-judgment discovery regarding the prosecution’s notes during jury selection and a motion for a new trial, both of which the trial court denied. The Georgia Supreme Court affirmed the trial court’s decisions, and the U.S. Supreme Court denied certiorari. Foster petitioned for a writ of habeas corpus in Butts County Superior Court and submitted a new Batson challenge based on the prosecutor’s notes obtained through the Georgia Open Records Act. The court denied Foster’s petition. The Georgia Supreme Court affirmed the denial of the writ. The U.S. Supreme Court granted certiorari.
jury cases
Baldwin v. New York (1970) – right to jury applied in any cases where there was a possibility of six months or more incarceration
Williams v. Florida (1970) - six person juries were acceptable
Apodaca v. Oregon (1972) - decisions need not be unanimous in non-capital cases, 10 of 12 ok.
Johnson v. Louisiana (1972) - 9 of 12 deemed constitutional
Ballew v. Georgia (1978) -five person juries are not acceptable in criminal cases
Burch v. Louisiana (1979) - six person jury verdicts must be unanimous.
