The Investigator Network Podcast

Sims V. Seattle (2024) 9th Circuit Court Opinion

This is a memorandum from the Ninth Circuit Court of Appeals addressing an appeal of a district court's denial of qualified immunity to police officers involved in a vehicle stop. The officers appealed the denial based on their actions during the stop, which included drawing weapons, frisking the plaintiff, and searching his trunk. The court found that the initial stop's escalation was unlawful, violating the plaintiff’s Fourth Amendment rights. Specific findings varied among the officers involved, with some receiving qualified immunity and others not. The court also lacked jurisdiction to fully review a related equal protection claim of racial discrimination. 
 
Click HERE for the ruling

United States V. Vayner

This appellate court opinion, U.S. v. Vayner, reverses a lower court's conviction for false identification. The core issue is the admissibility of a Facebook profile page purportedly belonging to the defendant, with the appeals court finding that the government failed to sufficiently authenticate the page. The opinion analyzes the legal standards for authentication under Federal Rule of Evidence 901, ultimately concluding that the improperly admitted evidence was prejudicial and necessitates a retrial. The case also examines related evidentiary issues, impacting the overall fairness and accuracy of the original trial.
 
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Hayes V. San Diego (California Supreme Court)

This is the Supreme Court of California's opinion in the case of Hayes v. County of San Diego. The case involves a lawsuit filed by Chelsey Hayes against the County of San Diego for the death of her father, Shane Hayes, who was killed by sheriff's deputies. The lawsuit revolves around whether the deputies' pre-shooting actions, including their decision to enter Shane's home without seeking additional information or psychiatric help, were negligent and contributed to his death. The Supreme Court ultimately ruled that the deputies' pre-shooting conduct can be considered as part of the totality of circumstances surrounding the use of deadly force, and the federal courts will determine whether their actions were negligent. Click HERE for ruling.

Mapp v. Ohio

The Supreme Court's ruling in Mapp v. Ohio, which overturned the previous decision in Wolf v. Colorado. The court decided that evidence seized in violation of the Fourth Amendment, which protects against unreasonable searches and seizures, is inadmissible in state courts. This means that the exclusionary rule applies to states, preventing the use of illegally obtained evidence. The court emphasized that this ruling upholds the individual's right to privacy and promotes judicial integrity, making the exclusionary rule an essential part of the Fourth and Fourteenth Amendments. Click HERE for case text.

US v Williams (2023)

This is a case summary from the United States Court of Appeals for the Sixth Circuit. The court affirmed the convictions of two individuals, Van Williams and Jamar Bloom, who were arrested for possession of cocaine and methamphetamine after a traffic stop. Williams and Bloom had challenged the legality of the stop and their subsequent arrests, arguing that the stop was unduly extended, that Bloom was illegally arrested, and that the search of their vehicle was illegal. The court, however, upheld the lower court's rulings, finding that the officers had reasonable suspicion to extend the traffic stop based on inconsistencies in Williams’s and Bloom’s travel plans and the discovery that Bloom was on probation. The court also found that probable cause for the search of the vehicle was established when a drug-sniffing dog alerted to the presence of narcotics, and that probable cause for Bloom’s arrest was established upon the discovery of drugs in the vehicle. Click HERE for case text.

US v Williams (2007)

 United States v. Williams, which addresses the constitutionality of a federal law prohibiting the pandering and solicitation of child pornography. The case centers on whether this law is overbroad or vague under the First Amendment and Due Process Clause of the Fifth Amendment. The Supreme Court ultimately ruled that the law is neither overbroad nor vague, upholding the conviction of the defendant, Michael Williams. This decision is significant because it broadens the scope of child pornography laws to include the act of proposing transactions in child pornography, even when the material itself may not actually depict real children. The dissenting opinion argues that this ruling undermines previous First Amendment protections for virtual child pornography and could lead to the suppression of constitutionally protected expression. Click HERE for case text

Scott v. Harris

The Supreme Court case, Scott v. Harris, examines the constitutionality of a police officer's use of a "Precision Intervention Technique" to stop a fleeing driver. The officer, Deputy Scott, rammed the fleeing motorist's car, rendering him a quadriplegic. The Court ultimately decided that Scott's actions were reasonable under the Fourth Amendment because the driver posed a substantial and immediate threat to public safety by recklessly driving at high speeds. The Court rejected the argument that the police should have simply ceased the pursuit, emphasizing the need to protect innocent bystanders from the danger of a reckless fleeing motorist. Click HERE for case PDF.

Mitchell v. Wisconsin (2019)

 Supreme Court of the United States on the case Mitchell v. Wisconsin. The case concerns the legality of a warrantless blood test conducted on a driver who was found unconscious after being suspected of driving while intoxicated. The Court concluded that the exigent-circumstances doctrine generally permits a blood test without a warrant in such cases, due to the pressing need for evidence and the potential for a driver to be taken to the hospital anyway for medical reasons. However, Justice Thomas believes that the warrantless blood test should be permitted regardless of the driver's consciousness, while the dissenting Justices argue that the state had time to obtain a warrant and that there is no categorical exception to the warrant requirement in drunk driving cases, even when the suspect is unconscious. Click HERE for the case text.

Investigations Case Law: State v. Stevens (Ohio Supreme Court 2023)

This is a case where a woman, Melannis Stevens, appealed a decision that found her guilty of multiple charges, including failure to stop after an accident and tampering with evidence. The case centered on whether or not the police violated her Fourth Amendment rights by using a drone to search her property without a warrant. The court ultimately ruled that the drone use did not violate her rights because the vehicle was not within the curtilage of her home and was therefore subject to the open fields doctrine, where a reasonable expectation of privacy does not exist. Click HERE for ruling.

Investigations Case Law: United States v. Tuggle (2021)

U.S. Court of Appeals case, United States v. Tuggle, in which the court examines whether the warrantless use of pole cameras to monitor a suspect's residence for an extended period constitutes a violation of the Fourth Amendment. The court concludes that, under current legal precedent, the use of pole cameras in this case did not constitute a search because the footage captured only areas visible to the public and the technology is commonly used. However, the court expresses concern about the implications of prolonged video surveillance for individual privacy and suggests that a reevaluation of Fourth Amendment protections in light of rapidly advancing technology may be necessary in the future. Click Here for Ruling