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Court Case Summaries Chapter Eight: Criminal Law and Procedure
Loving v. Commonwealth of Virginia
In 1958, the Lovings, an interracial couple, were married in the District of Columbia, although they were both residents of Virginia. Shortly after returning to Virginia, they were indicted and convicted of violating the state's miscegenation statutes. The Lovings filed a motion in the state court to vacate the judgment and set aside their sentences on the ground that the statutes were unconstitutional. The judge denied the motion, and the plaintiffs appealed to the Supreme Court of Appeals of Virginia. In the meantime, prior to the state judge rendering a decision, the plaintiffs filed a class action suit in the U.S. District Court. The federal court continued the case so that the Lovings could present their claims to the highest state court. That court upheld the miscegenation statutes.
The U.S. Supreme Court reversed the convictions and expressly ruled that the Virginia statutes were predicated upon "invidious racial discriminations" and thus violated the equal protection clause and the due process clause of the Constitution.
People v. Shaughnessy
The defendant, while a passenger in an automobile, was driven onto private property, where she was stopped and charged with violating an ordinance prohibiting entry onto private property without the owner's permission. At the close of her trial, the defendant moved to dismiss on the grounds that the applicable ordinance was unconstitutional. The court dismissed the case, but not on constitutional grounds. Instead, the court held that since the defendant was merely a passenger in the automobile, her presence on the private property was not voluntary and, therefore, she could not be held criminally responsible.
State v. Gordon
The defendant, Gordon, escaped from authorities in Vermont. While in Maine, he and a friend experienced engine trouble and began to look for another vehicle. They spotted a Chevelle with keys in it. The friend got into the car, pointed a gun at the car's owner, and he and Gordon told the owner that they would "take care of [the car] and get it back as soon as possible." The defendant was charged with armed robbery and, in a separate indictment, with assaulting a police officer (based on a later incident). A jury found the defendant guilty of armed robbery. He appealed, contending that since he intended to return the Chevelle, he did not have the specific intent necessary to constitute the crime. The Supreme Judicial Court of Maine denied Gordon's appeal. It ruled that the jury could have found that the defendant's indifference regarding the return of the automobile indicated the specific intent to deprive the owner of his property permanently.
Commonwealth v. Berggren
The defendant, while operating a motorcycle, failed to stop when pursued by a marked police cruiser for speeding. While entering an intersection, the cruiser's wheels locked and it hit a tree, resulting in the police officer's death. The defendant was charged with negligent vehicular homicide. Prior to trial, the district court granted the parties' joint motion to report the question of whether the facts would support a conviction pursuant to the applicable statute. The report was transferred to the supreme judicial court on its own motion. It held that the standard of proximate causation in tort law is the standard to be applied to the criminal statute at issue. Therefore, since the officer's death was a foreseeable consequence of the defendant's actions, the court concluded that a conviction for negligent vehicular homicide could be supported.
United States v. Scott
Scott was convicted in U.S. District Court of one count of conspiracy to manufacture methamphetamine and one count of manufacturing the unlawful drug. He appealed his conviction on the ground that the district court refused to instruct the jury on the defense of coercion. Scott asserted that a co-defendant forced him to commit the crimes under fear of his own death or the death of a family member. The U.S. Court of Appeals for the Tenth Circuit determined that Scott had a reasonable opportunity to escape the threatened harm and, therefore, he failed to satisfy one of the three criteria necessary for proffering a coercion defense. As a result, the appeals court affirmed the lower court's denial of the defendant's request for an instruction on the coercion defense.
Draper v. United States
A reliable informant provided a federal narcotics agent with detailed information that petitioner Draper would be arriving in Denver by train from Chicago, on one of two mornings, wearing specified clothing, and carrying three ounces of heroin. Relying on that information, the federal agent watched the train station and witnessed an individual fitting the precise description alighting from the specified train on the identified date, wearing the exact clothing described by the informant. The agent executed a warrantless arrest and, upon searching Draper, found heroin and a syringe. At trial, Draper moved to suppress the evidence, claiming that the agent's information was hearsay, which could not be used as grounds for conducting a warrantless arrest, and even if hearsay had been lawfully considered, the agent did not have probable cause or reasonable grounds to believe that Draper had committed or was committing a narcotics violation.
The U.S. Supreme Court held that the denial of the motion to suppress was proper. Since the agent personally verified all the informant's information except for whether Draper was carrying contraband, the Court concluded that probable cause and reasonable grounds to believe Draper was committing a crime existed sufficient to render Draper's arrest, and the subsequent search and seizure of the heroin, lawful.
Charles T. Dickerson v. United States
Dickerson, the defendant/appellant in this bank robbery case, made a voluntary statement to police without having been previously advised of his Miranda rights. The district court, in conformity with the Miranda decision, suppressed the statement. The government was successful in its interlocutory appeal to the U.S. Court of Appeals for the Fourth Circuit.
The Fourth Circuit agreed with the district court that no Miranda warnings had been administered but reversed the trial court's suppression order. The appeals court concluded that the U.S. Supreme Court had not grounded its Miranda decision in the U.S. Constitution and that a statute enacted by Congress, 18 U.S.C. 3501 prevented the suppression of evidence in this case. Dickerson successfully petitioned the U.S. Supreme Court for a writ of certiorari, and the Supreme Court concluded that the Fourth Circuit was in error. Miranda, said Chief Justice Rehnquist, was grounded in the U.S. Constitution and was correctly applied by the district court to exclude Dickerson's statement.
Crystal M. Ferguson v. City of Charleston
The ten pregnant women who were the plaintiffs in this lawsuit were obstetrical patients at a public hospital known as the Medical University of South Carolina. These women were unknowingly and without consent subjected to urine testing for the purpose of determining whether they were harming their unborn babies by using cocaine while pregnant. The testing was conducted pursuant to a comprehensive policy primarily developed by the City Solicitor. Participating in the development of this policy were representatives from the local police, hospital, social service department, and substance abuse commission.
These plaintiffs all tested positive when tested for cocaine and each was arrested by the police. The plaintiffs alleged that they had been subjected to unreasonable searches and seizures in violation of the Fourth Amendment. A jury concluded that the women had consented to the testing and found in favor of the City. The plaintiff's unsuccessfully appealed to the U.S. Court of Appeals for the Fourth Circuit. The Supreme Court reversed the Fourth Circuit's judgment because the "special needs" analysis did not apply and the warrantless search was unconstitutional.
Adams v. Williams
While alone in a high-crime area in Bridgeport, Connecticut, a police officer was approached by a known informant who relayed that an individual seated in a nearby automobile possessed narcotics and had a gun at his waist. Based on the information, the officer conducted a Terry stop and frisk on the individual, the respondent Williams. Specifically, the officer asked Williams to get out of his car but, instead, Williams rolled down the car window, and the officer reached inside and removed a fully loaded gun from Williams' waistband. The search incident to the arrest revealed heroin, a machete, and a second gun.
At trial, Williams contended that the stop was not justified and thus, the fruits of the search should not have been admissible. His conviction was affirmed by the Supreme Court of Connecticut, and his federal habeas corpus petition was denied by the U.S. District Court and by a divided panel of the Second Circuit Court of Appeals. On rehearing of the full panel (en banc), the circuit court reversed the conviction. The U.S. Supreme Court, in turn, reversed the Second Circuit's decision and upheld the conviction. The Supreme Court held that the informant's tip had a sufficient "indicia of reliability" to allow the officer to investigate the situation. When Williams rolled down his window instead of getting out of the car, the officer was permitted to ensure his safety by taking the concealed weapon. Probable cause, therefore, existed to arrest Williams for unlawful possession of a weapon, and the search conducted incident to that arrest was lawful.
New Jersey v. T. L. O.
T. L. O., while a 14-year-old public high school freshman, was caught smoking in the lavatory. When questioned by the assistant vice principal, T. L. O. claimed that she did not smoke. A cursory search of her purse revealed a package of cigarettes and rolling papers. Upon seeing the rolling papers, the assistant vice principal conducted a thorough search of the purse and found a small quantity of marijuana, a pipe, empty plastic bags, and other items implicating T. L. O. in drug dealing. As a result, T. L. O. was charged with delinquency in juvenile court. Her motion to suppress the evidence was denied, and she was adjudged a delinquent. The appellate division affirmed the trial court's decision but the New Jersey Supreme Court reversed and ordered the evidence found in the purse suppressed based on Fourth Amendment grounds.
The U.S. Supreme Court granted the state of New Jersey's petition for certiorari and held that Fourth Amendment principles do apply to searches and seizures conducted by public school officials. School officials are state actors and are not entitled to immunity based on a parens patriae theory. In determining whether the search was reasonable under the Fourth Amendment, the Court balanced the school's need to maintain order against the student's expectations of privacy. The Court concluded that a school official need not obtain a warrant before searching a student suspected of violating a school rule or committing a crime. Based on a twofold inquiry about whether the search was "justified at its inception" and then "reasonably related in scope to the circumstances," the Court held that the initial search conducted on T. L. O.'s purse for cigarettes was not unreasonable, and that once the rolling papers were discovered, the search for marijuana was also legitimate. The Court reversed the state supreme court's decision to exclude the evidence from T. L. O.'s delinquency proceedings.
United States v. Salerno
Two alleged members of the Genovese family of La Cosa Nostra were arrested on multiple racketeering charges under the Racketeer Influenced and Corrupt Organizations Act (RICO). At their arraignment, the government moved to have them detained without bail pursuant to the Bail Reform Act on the ground that the safety of the community or any person would be endangered by their release. The district court granted the detention motion, but on appeal, the Second Circuit reversed, ruling that the statute was facially unconstitutional since it permitted pretrial detention on the speculation that an arrestee was likely to commit a future crime.
The U.S. Supreme Court granted certiorari and reversed, holding that the act did not violate either the due process clause or the Eighth Amendment. As to due process, the Court stated that pretrial detention is regulatory, not punitive, and served compelling governmental interests. The Court also rejected the argument that the Eighth Amendment's proscription against excessive bail requires only consideration of flight, not danger, in deciding whether bail should be granted.
Justices Marshall and Brennan dissented, arguing that allowing innocent people to be jailed indefinitely pending trial is tantamount to creating a police state.
Sullivan v. Louisiana
In this case, the defendant appealed a constitutionally erroneous instruction regarding reasonable doubt, which was given by the trial court in a murder case. Despite the instruction, the defendant lost his appeal in the state supreme court because that court ruled that the error was harmless. The U.S. Supreme Court granted certiorari to determine whether an erroneous instruction on the meaning of reasonable doubt can amount to harmless error. The Court ruled that Louisiana's instruction could not amount to harmless error. Denying a defendant the right to a beyond-a-reasonable-doubt jury verdict was a "structural error" that required reversal.
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