Amicus Brief Arguing De Facto Life Sentences for Juveniles Violate the Eighth Amendment
This amicus brief argues that mandatory term-of-years sentences that deny juvenile offenders a meaningful opportunity for release function as unconstitutional life-without-parole sentences under the Eighth Amendment. Relying on Miller v. Alabama, Graham v. Florida, and Jones v. Mississippi, the brief contends that constitutional analysis must focus on the real-world effect of the imposed sentence rather than the label. It explains […]
Motion to Exclude Ballistics Expert Evidence
This brief follows an extensive Frye hearing on bullet matching evidence and incorporates extensive criticism from the scientific community, an explanation of the unintended impact that a narrow definition of the “relevant scientific community” can have, and evidence of the ways that cognitive bias impermissibly taint pattern-matching evidence.
Shotspotter – Civil Complaint – ShotSpotter Is Unreliable and Ineffective
p. 13-59 overview studies of Shotspotter accuracy and racially biased implementation
Amicus Brief – Bite mark comparison testimony is inherently unreliable
p. 35-65 detail research demonstrating bite-mark comparison has “no empirical support” high error rates, and is not accepted within the scientific community
Amicus Brief – Police Violence Increases Risk of False Confessions
p. 14 to 21 cites research on false confession risk factors and police techniques that increase risk
Motion to Bar Testimony – Shaken Baby Syndrome
Focusing on retinal hemorrhages, this motion cites research showing no proven correlation between shaking and retinal hemorrhage, as well as studies documenting other (non-shaking) causes of retinal hemorrhage.
Motion for attorney conducted voir dire
p. 17 – 25 explain why attorney-conducted voir dire leads to increased self-disclosure and better assessment of juror bias.