Petition for Relief under Racial Justice Act
This motion incorporates studies of implicit bias and racially discriminatory policing in San Diego. Studies referenced describe disparities in how police speak to drivers of different races as well as disparities in post-stop outcomes.
Shotspotter – Civil Complaint – ShotSpotter Is Unreliable and Ineffective
p. 13-59 overview studies of Shotspotter accuracy and racially biased implementation
Amicus Brief to Exclude Drug Recognition Expert
Pages 1-4 discuss the history and development of the DRE program; pages 6-10 explain how the DRE test fails Rule of Evidence 702 because it does not assist the trier of fact to understand a fact in issue and the officers who testify about it are not qualified in the relevant field of knowledge; and […]
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 […]
Amicus Brief – Shotspotter
Overview of Shotspotter’s unreliability and contribution to discriminatory police practices
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, […]
Memorandum to Suppress First-Time, In-Court Identification Under Due Process Clause
Argument that using in-court IDs as the only identification in case is a violation of the Due Process Clause because they create a substantial risk of misidentification. Social science studies cited throughout, specifically supporting reliability concerns (pgs. 10-12) and policy arguments (pgs. 13-15)
