Motion for Disability Accommodations
This motion argues that courts must provide reasonable accommodations under the ADA and due process principles to ensure defendants with disabilities can meaningfully participate in their defense. It explains that court proceedings are protected services under Title II and that failure to accommodate—such as denying additional time, communication support, or assistive technology—can render a defendant […]
Motion for Jail Accommodation Pursuant to the ADA
This motion argues that jails and pretrial detention facilities must provide reasonable accommodations under Title II of the ADA to ensure equal access to programs, services, and basic conditions of confinement. It explains that denial of accommodations—such as medical care, accessible housing, or participation in programming—constitutes unlawful discrimination and can exacerbate physical and mental health […]
Motion to Compel Discovery Related to Veracity of Presumptive Field Drug Tests
This motion seeks discovery concerning the reliability of colorimetric presumptive field drug tests, arguing that these tests are unreliable and prone to high false-positive rates. Drawing on empirical research and audits from jurisdictions nationwide, the motion explains that common legal substances frequently trigger positive results and that accuracy varies widely based on officer training, storage, and administration. It argues […]
Amicus Brief Challenging Lifetime Felony Disarmament Under Bruen
This amicus brief argues that Washington’s lifetime felony firearm disarmament statutes violate the Second Amendment as applied to a person convicted of vehicular homicide, because the State cannot identify a relevant historical analogue as required by Heller, Bruen, and Rahimi. The brief explains that the Supreme Court’s text and history test has been applied selectively, […]
Motion To Compel Discovery Pursuant to Maryland Rule 4-262 Concerning Operation and Reliability of Flock Data
This motion argues that Flock’s ALPR and Vehicle Fingerprint® systems are secretive, unregulated, and error-prone artificial intelligence tools whose reliability cannot be assessed without robust discovery into how they function, how they were developed and trained, and what their error rates are (pp. 4-7). It explains that machine-learning “hallucinations,” environmental conditions (weather, lighting, camera noise), […]
Motion to Invalidate Warrant and Suppress Evidence due to Insufficient Probable Cause Grounded in Unreliable Flock Data
This motion seeks to invalidate a warrant and suppress all resulting evidence where the warrant rests solely on Flock data. It explains that Flock’s machine-learning model generates conclusions based on a non-public AI model with an unknown error rate, is vulnerable to hallucinations, and is highly sensitive to weather, lighting, noise, and partial plate captures, […]
Brief in Support of Motion for Admission and Funding for an Antiracism Expert Witness
This brief argues that funding for and admission of an antiracism expert witness is necessary to ensure due process and fairness under both the U.S. and Massachusetts Constitutions, as well as Mass. Gen. Laws ch. 261, § 27C. An antiracism expert’s testimony would assist the factfinder in understanding how structural and interpersonal racism shape perceptions, […]
Motion in Limine to Exclude Evidence of Substance Use
This motion argues that evidence of a client’s alleged substance use must be excluded because it constitutes impermissible character evidence under FRE 404(a), poses a high risk of unfair prejudice under FRE 403, and invites unqualified medical opinion testimony in violation of FRE 701. Citing social-science research showing that jurors associate substance use with immorality, […]
Brief in Support of Motion to Prohibit [Drug/Alcohol] Testing as Mandatory Probation Condition
This brief argues against mandating regular drug or alcohol testing as a probation condition for a client who does not have a history of substance abuse related to their offense. It is written citing MCL 771.3(11), which requires probation conditions to be tailored to the individual’s assessed risks and needs, but can be easily adapted […]
Daubert Motion to Exclude Firearm and Toolmark Evidence
This motion seeks exclusion of firearm and toolmark identification evidence under Daubert and Michigan Rule of Evidence 702, arguing that the AFTE method lacks foundational scientific validity and relies on subjective, unarticulated examiner judgment. Drawing on the National Academy of Sciences and President’s Council of Advisors on Science and Technology reports, the motion explains that […]