Case Summaries

Criminal Law & Procedure

[07/23] US v. Clark
Convictions for possession and conspiracy to distribute cocaine are affirmed where: 1) evidence of prior drug relationships was properly admitted; 2) evidence of the details of a physical attack in which defendants were not involved was not prejudicial; 3) a photo intended to be used to impeach a witness was properly excluded; 4) a prior statement of a witness was properly excluded as irrelevant; and 5) the prosecutor's characterization of a defendant's anticipated closing argument as a "standard" argument made by drug defendants was improper, but did not prejudice defendant.

[07/23] Gil v. Reed
In an inmate's negligence, malpractice, and civil rights suit against prison medical staff, summary judgment for defendants is reversed where the record contained sufficient evidence to show genuine issues of material fact on: 1) inmate's Eighth Amendment claim that prison staff were deliberately indifferent to his medical needs; and 2) whether defendants had met the standard of care, using the state-law standard as required by the Federal Tort Claims Act.

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Habeas Corpus

[07/22] Fratta v. Quarterman
Grant of a habeas corpus petition in a capital murder case is affirmed, and request for a certificate of appealability on other issues is denied, where: 1) the admission at trial of the custodial confessions of codefendants violated the Confrontation Clause; 2) the fact that out-of-court statements of a coconspirator are admissible under state evidentiary law is not sufficient to meet the requirements of the Confrontation Clause; 3) the admission of the out-of-court statements of a coconspirator at defendant's trial violated the Confrontation Clause; and 4) the error was not harmless.

[07/22] Crawley v. Dinwiddie
Denial of habeas relief is affirmed where there is no clearly established federal law relevant to petitioner's claim that his counsel was ineffective in accommodating petitioner's preference to be found competent, despite his personal misgivings and the contrary opinions of a doctor and the prosecutor.

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