Constitutional Validity Archives

PC 2017-755

Post author:Staff
Post published:May 24, 2019
Post category:PC

In OCCA case No. PC 2017-755, the petitioner appealed his conviction for First Degree Murder. In a published decision, the court decided to vacate the previous sentence and allow for resentencing with a jury. The dissenting opinions argued against the majority decision, indicating that the judge had the discretion to deny jury resentencing based on prior waivers. The case started when the petitioner was just seventeen years old and pleaded guilty to First Degree Murder in 2006. Originally, he was sentenced to life in prison without the chance for parole. After some time, he claimed that this sentence was unfair because he was a minor when he was sentenced. The court agreed and decided to let him be resentenced but had to deal with the issue of whether his resentencing should involve a jury. The petitioner argued that since he was seeking resentencing, he should be allowed a jury trial. However, the state disagreed, pointing out that he had waived his right to a jury trial when he originally pleaded guilty. The judge decided that because of this waiver, he didn’t have to give the petitioner a jury for resentencing. In this case, the court looked at previous decisions that said when a juvenile is sentenced to life without parole, they should have a jury trial unless they give up that right. The majority of the court found that the petitioner did not truly waive his right to a jury for the resentencing, as he was relying on new rules from recent important cases. Ultimately, the court decided that it was wrong for the judge to deny the jury resentencing. They chose to vacate that decision and said the case should go back to the lower court to figure out the right way to do the resentencing, with the ability to include a jury if the petitioner asked. The dissenting opinions argued that the judge had actually acted correctly by denying the request for a jury because the petitioner had already waived that right back when he pleaded guilty. They believed that the rules shouldn’t allow a person to change their mind long after the original decision. The court ordered that the petitioner’s guilty plea and conviction were still valid, but they needed to follow the correct process under the law for the new sentencing.

F-2017-622

Post author:Staff
Post published:May 16, 2019
Post category:F

In OCCA case No. F-2017-622, Dakota William Stewart appealed his conviction for two counts of First Degree Manslaughter and one count of Unlawful Possession of a Controlled Dangerous Substance. In a published decision, the court decided to affirm Stewart's judgment and sentence. One member of the court dissented. Stewart was involved in a car accident where his vehicle collided with another, resulting in two deaths. He was critically injured and taken to the hospital, where, without a warrant or his consent, a nurse drew blood to test for drugs. The blood tests showed the presence of methamphetamine and marijuana. Stewart contested the legality of the blood draw, arguing it violated his constitutional rights against unreasonable searches and seizures. Initially, the district court denied his motion to suppress the blood evidence, citing Oklahoma law that permits blood draws without a warrant in severe vehicle accidents. The court referenced previous rulings that support this statute. However, the higher court reviewed these past decisions, particularly focusing on whether the law upheld constitutional protections. The decision highlighted that legal procedures must include an individualized assessment of probable cause by a neutral magistrate to justify warrantless searches. The court found that the law in question, while attempting to streamline procedures for serious accidents, created a blanket rule that bypassed this necessary step. Ultimately, the court ruled that even if the blood draw violated constitutional principles, the good faith reliance on the statute by law enforcement meant the results could still be admitted as evidence. Therefore, the court upheld Stewart's conviction, emphasizing the importance of proper procedure while acknowledging the complexities involved in such tragic incidents.

C-2016-40

Post author:Staff
Post published:February 9, 2017
Post category:C

In OCCA case No. C-2016-40, Deandre Lashawn Henderson appealed his conviction for assault with a dangerous weapon and possession of a firearm after a former conviction of a felony. In a published decision, the court decided to grant part of his appeal. The court affirmed the convictions for Counts 1 and 5, but reversed and vacated the judgments for Counts 2 through 4. One justice dissented. The case began when Henderson entered a negotiated Alford plea, which means he maintained his innocence but accepted the plea for the sake of a more favorable sentence. He was sentenced to twenty years for the assault counts and ten years for the possession count, all to be served concurrently, meaning at the same time. Later, Henderson wanted to withdraw his plea. He claimed that his plea was not made knowingly, intelligently, or voluntarily. He also said that he did not receive effective help from his lawyer and that the trial court should have appointed a different lawyer due to a conflict of interest. During the appeal, the court looked closely at whether Henderson's plea was made voluntarily and if the district court had the authority to accept it. The court found that Henderson's plea was indeed voluntary because he knew the charges and the consequences. His choice to accept the plea was motivated by a desire to reduce his overall prison time, especially given the evidence against him. However, the court agreed that Henderson's lawyer should have argued that some of the charges violated the double jeopardy clause, which means he shouldn't be punished multiple times for the same act. The court found that the counts for assault stemmed from the same event and that it was wrong to punish him multiple times for it. Therefore, while verifying his conviction for some counts, the court ruled that the counts of conviction for assault with a dangerous weapon were not valid as they violated his rights. This decision meant that Henderson would not have to serve time for those three convictions but would still be sentenced for the other charges. Overall, the court upheld some aspects of the conviction but also corrected parts that were not handled properly.