Justia Class Action Opinion Summaries

After a jury trial, Defendant was convicted of aggravated murder, aggravated robbery, and having weapons under disability. Prior to trial, Defendant filed a suggestion of incompetence to stand trial and a plea of not guilty by reason of insanity. A psychologist conducted a court-ordered evaluation on the issues of Defendant’s competency and sanity. Defendant later withdrew the defenses. On appeal, Defendant argued that the trial court violated his Fifth Amendment privilege against self-incrimination when it allowed the psychologist to testify during trial. The court of appeals reversed Defendant’s convictions for aggravated murder and aggravated robbery, concluding that Ohio Rev. Code 2945.371(J) prohibits the use of statements made by a defendant in a psychiatric evaluation against the defendant on the issue of guilt in a criminal action. The Supreme Court affirmed, holding (1) when a defendant asserts a mental-capacity defense, resulting in the court ordering a psychiatric evaluation, but then the defendant wholly abandons the defense, a psychologist’s testimony regarding the defendant’s feigning of mental illness during the court-ordered evaluation is inadmissible in the state’s case-in-chief pursuant to section 2945.371(J); and (2) the trial court’s admission of the psychologist’s testimony in this case was not harmless error. View "State v. Harris" on Justia Law

The Special Management Unit housing unit within the Lewisburg U.S. Penitentiary houses inmates identified as having violent tendencies or having a history of gang involvement while incarcerated. Inmates assigned to the SMU are confined to their cells for 23 hours a day, but can spend the remaining hour in a recreation cage. When first assigned to the SMU, inmates are interviewed by prison officials to ensure that inmates who may be hostile to each other are not housed in the same cell. Shelton, a USP inmate, filed a purported class action, alleging that the defendants have engaged in a pattern, practice, or policy of improperly placing inmates who are known to be hostile to each other in the same cell. He also claims that the defendants fail to intervene when the predictable inmate-on-inmate violence erupts, and that defendants improperly restrain inmates who refuse cell assignments with inmates who are known to be hostile to them. The district court denied Shelton’s motion for class certification and granted defendants’ motion for summary judgment. The Third Circuit affirmed dismissal of a Federal Tort Claims Act claim, but vacated the denial of class certification and summary judgment as to an Eighth Amendment claim. View "Shelton v. Bledsoe" on Justia Law

Defendants appealed an order certifying a class and a subclass of inmates in Arizona's prison system who claim that they are subject to systematic Eighth Amendment violations. Defendants argued that the district court abused its discretion in concluding that plaintiffs have demonstrated commonality and typicality under Rule 23(a). The court concluded that the district court did not abuse its discretion in determining that plaintiffs' claims depend upon common questions of law or fact that are answerable in one stroke. Here, plaintiffs are all inmates in ADC custody and each declares that he or she is being exposed, like all other members of the putative class, to a substantial risk of serious harm by the challenged ADC policies. Therefore, the court concluded that the district court did not err in determining that plaintiffs have satisfied the commonality and typicality requirement of Rule 23(a). Finally, the district court did not abuse its discretion in concluding that a single injunction and declaratory judgment could provide relief to each member of the proposed class and subclass. Accordingly, the court affirmed the judgment of the district court.View "Parsons v. Ryan" on Justia Law

At issue in this case were amendments to the Sex Offender Registry Law that the Governor signed into law on July 12, 2013, including amendments that would require the Sex Offender Registry Board (SORB) to publish on the Internet information contained in the sex offender registry regarding individuals given a level two or three classification. On July 5, 2013, Plaintiffs, as putative representatives of a class of persons presently and prospectively classified as level two sex offenders, filed a complaint for declaratory and injunctive relief seeking an injunction barring SORB from publishing registry information on the Internet of the class of level two offenders. The Supreme Judicial Court declared unconstitutional the retroactive application of the amendments to the extent they would require the Internet publication of the registry information of individuals who were finally classified as level two sex offenders on or before July 12, 2013 but noted that SORB was allowed to publish on the Internet the registry information of any individual who was given a final classification as a level two sex offender after July 12, 2013.View "Moe v. Sex Offender Registry Bd." on Justia Law

William Glick filed a class action suit against Raymond Wohl, in his official capacity of the clerk of the municipal court, among other defendants, seeking declaratory and equitable relief related to Glick's municipal court sentences he alleged to be void for imposing unlawfully excessive court costs. The common pleas court determined that Glick’s class action against Wohl was viable, declared that multiple costs assessed against Glick as part of his sentence were unlawful, and held that Glick and other class members who had been assessed unlawful costs were owed a refund. The court of appeals reversed, concluding that the class action was not viable, and remanded for entry of summary judgment in favor of Wohl. The Supreme Court affirmed, holding (1) the relief requested by Glick in his class action was in substance a request to vacate a portion of a judgment of the municipal court; and (2) because a court of common pleas has no power to vacate an order rendered by a municipal court, summary judgment should have been granted in favor of Wohl. Remanded. View "Lingo v. State" on Justia Law

In consolidated appeals, defendants the Alabama Department of Corrections, various department officials, and Governor Robert Bentley, appealed in case no. 1111588, the trial court's determination limiting certain deductions from work-release earnings for inmates. In case no. 1120264, Jerry Mack Merritt (as sole representative of the plaintiff class) cross-appealed, raising numerous challenges to the trial court's final judgment. After its review, the Supreme Court dismissed the appeal in case no. 1120264 as untimely filed; in case no. 1111588, the Court reversed and remanded. The Court found that the department's interpretation of section 14-8-6 as permitting its collection of charges, which were not incident to the inmate's confinement, in excess of a 40% withholding cap established by that statute was both reasonable and consistent with the statutory language. View "Thomas v. Merritt" on Justia Law

Appellant was convicted of two counts of aggravated robbery, two counts of theft of property, and one count of second-degree battery. After the court of appeals affirmed on direct appeal, Appellant filed a petition for postconviction relief, alleging ineffective assistance of counsel. The circuit court denied the petition after a hearing. The Supreme Court affirmed, holding that trial counsel was not ineffective (1) for failing to move for a directed verdict at trial, as a directed-verdict motion would not have been successful; (2) for "opening the door" to certain testimony, as counsel's tactical decision about how to cross-examine the witness was supported by reasonable professional judgment; and (3) in investigating and preparing Appellant's case.View "Mason v. State" on Justia Law

Defendant was charged with driving under the influence of alcohol and driving with a blood-alcohol concentration of 0.08 percent or more. During the trial proceedings, the trial court excluded expert witness testimony challenging the reliability of the breach-alcohol testing machines used on Defendant. The jury was unable to reach a verdict on the generic charge but found Defendant guilty of driving with 0.08 percent or more of alcohol in his blood. The court of appeals reversed, concluding that the trial court committed prejudicial error in excluding the challenged expert testimony. The Supreme Court reversed and affirmed Defendant's conviction, holding that the trial court properly excluded the challenged expert testimony, holding that the fundamental reliability of a federally approved, properly calibrated and employed breath-testing machine used in the application and enforcement of a per se statute is a matter that has been determined as policy by the Legislature, and a defendant's expert witness may not invite a jury to nullify that determination in the manner at issue here.View "People v. Vangelder" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree murder. Defendant appealed, arguing (1) under Kansas' version of a stand-your-ground-law in effect at the time of the crime, he was immune from prosecution; and (2) he was deprived of a fair trial due to prosecutorial misconduct. The Supreme Court affirmed Defendant's convictions, holding (1) Defendant was not entitled to relief on his argument that he was immune from prosecution under the stand-your-ground statute because he made the argument for the first time on appeal, and the statute must be asserted before trial or opens or a dispositive plea is entered; and (2) the prosecutor made an incorrect statement of law about the jury's process during the rebuttal portion of closing argument, but this error was harmless.View "State v. Jones" on Justia Law

Defendant was convicted of two counts of first-degree murder, two counts of attempted first-degree murder, and burglary of a dwelling. The trial court imposed death sentences for the murders of both victims. Defendant appealed, raising several issues with regard to the penalty phase that led to the imposition of the death sentences. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) any error in the trial court's finding of the aggravating factors was harmless beyond a reasonable doubt; (2) the trial court did not err in allowing victim impact statements or in admitting photographs of the murder victims; (3) the imposition of the death penalty in this case was proportionate and supported by the applicable aggravating and mitigating factors; and (4) sufficient evidence in the record supported Defendant's convictions.View "Kalisz v. State" on Justia Law