Motion for Judgment of Acquittal Where Only Evidence Supporting Possession with Intent to Distribute is Amount of Methamphetamine Found
Draft motion arguing that finding many grams of methamphetamines does not necessarily support a conviction for possession with intent to distribute. Bottom of p. 1 through p. 3 explains that people addicted to methamphetamines use more frequently and in higher dosages than first-time users, using as much as one gram per day and rarely (but […]
Shotspotter – Civil Complaint – ShotSpotter Is Unreliable and Ineffective
p. 13-59 overview studies of Shotspotter accuracy and racially biased implementation
Amicus Brief in Support of Considering Race in a Reasonable Person Analysis
Cites studies demonstrating racial disparities in incidents of police violence, being stopped by police, and resulting perception of police
Marijuana Smell Alone Should Not Justify A Search
Based on six years of data of police stops in Philadelphia based on the smell of marijuana, this brief overviews how its use as a justification for a search has vastly increased the number of searches conducted, but less than 20% of the searches relying on the presence of marijuana actually discovered contraband. The brief […]
Affidavit of Expert in Facial Recognition Technology
This document was filed in support of a motion to compel discovery of the underlying source code, parameters, error rates, input data, results, reports, analyst, and confidence scores of the Facial Recognition program used in a criminal case. The expert explains the steps involved in a facial recognition search and areas where subjective human decisions […]
False Arrest & Imprisonment Complaint – inaccuracy and racial bias in facial recognition technology
Civil rights complaint about problems with facial recognition technology – pgs. 9-12 collect research about errors with when images are of low quality, angles are different, resolution is bad; pgs. 12-15 collect research showing facial recognition algorithms are racially biased; pgs. 15-16 collect data about jurisdictions that have banned use of facial recognition technology because […]
Amicus Brief – Court should consider race in a “reasonable person” analysis
Incorporating statistical evidence of racial disparities in police stops and police violence, this brief argues that “what constitutes “suspicious” or “abnormal” behavior for Fourth Amendment purposes must take into account the realities of racism and police violence experienced by communities of color” and that any totality of the circumstances analysis must consider “the fraught, frightening, […]
Brief Arguing that the Smell of Marijuana Could Not Have Been Detected During a Traffic Stop So No Probable Cause to Search
p. 10-12 discuss a study that found that people with normal smell identification abilities could only smell a 5-pound bag of marijuana in a trunk 13% of the time, and that 10% of the time people thought they smelled marijuana when there was none. p. 12-13 argues that an officer can impermissibly taint a search by suggesting […]
