Motion to Exclude Prior Conviction Evidence Under Evidence Rule 609 and State Constitution
This motion seeks to exclude evidence of the accused’s prior convictions under Washington ER 609 and the state constitutional provisions protecting the right to a fair trial and to testify. Drawing on social science research, it argues that prior convictions are poor predictors of courtroom truthfulness and that jurors frequently misuse them as propensity evidence—concluding […]
Motion for Funding for a Juvenile Brain-Development Expert
This motion seeks public funding for a juvenile brain-development expert to explain how developmental immaturity affects a young person’s ability to assess risk, anticipate consequences, and foresee that participation in an underlying felony could result in death. Written in the context of a New York felony-murder prosecution, the motion argues that foreseeability is central to […]
Motion to Suppress Statement of Juvenile Client Subject to Police Deception
This motion seeks suppression of statements obtained from a juvenile through
deceptive interrogation tactics, false evidence claims, and/or promises or suggestions of
leniency. It argues that courts must evaluate voluntariness under the totality of the
circumstances, giving particular weight to the client’s age, maturity, education,
developmental or mental-health vulnerabilities, experience with law enforcement,
interrogation conditions, and comprehension of Miranda rights. Drawing on adolescent-
development research, the motion explains that youth are more susceptible to authority,
more focused on escaping immediate stress, less able to assess long-term
consequences, and consequently at heightened risk of involuntary waivers and false
confessions. It also surveys law-enforcement guidance and state statutes recognizing
the dangers of using deception against children. The motion argues that statements
elicited through deception or inducements should be presumed involuntary or,
alternatively, that the court should conduct a hearing requiring the prosecution to prove
voluntariness beyond a reasonable doubt.
Motion for Evidentiary Hearing to Suppress Fruits of a Pretextual Traffic Stop
This motion argues that Pennsylvania courts should recognize a state constitutional remedy for pretextual and racially discriminatory traffic stops under Article I, § 8 and Pennsylvania’s equal protection provisions. Drawing on empirical research, including a study linking Whren’s permissive pretext doctrine to increased racial profiling, and data showing Black drivers are stopped and searched at […]
Motion to Preclude Prosecution from Referring to Complainant as a “Victim”
This motion argues that referring to a complainant as a “victim” improperly bolsters credibility, undermines the presumption of innocence, and prejudices the accused by presupposing that a crime occurred. Drawing on social science research, including a study finding that jurors were more likely to presume guilt when an accuser was labeled a “victim” rather than […]
Motion to Suppress “High-Crime Area” Justification for Terry Stop
This motion argues that police reliance on a “high-crime area” designation should carry little or no weight in the reasonable suspicion analysis because the label is vague, non-particularized, and often untethered to actual crime data. Drawing on recent case law and empirical research, it contends that such designations are inconsistently applied, racially biased, and frequently […]
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 […]
Appellate brief argues racially disparate LWOP sentencing and racially biased trial language violate the California Constitution and Racial Justice Act
This appellate brief argues that mandatory LWOP for an 18-year-old Latine individual violates the California Constitution because LWOP is disproportionately imposed on young people of color. Citing social science and sentencing data, the brief explains how racial stereotypes shape extreme sentencing outcomes that disproportionately expose young Black and Latine people to LWOP. The brief also […]
Brief Challenging Admissibility of Abortion Contemplation and Lack of Prenatal Care and Invalid Miranda Waiver
This brief argues that evidence of abortion contemplation, lack of prenatal care, and other lawful prenatal decisions is irrelevant and unduly prejudicial when offered to prove postnatal homicidal intent. It further contends that statements obtained after police repeatedly misinformed the suspect about her right to appointed counsel must be suppressed because any waiver of counsel […]