New Jersey v. Scott, Appellant’s Brief

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This pleading addresses racial bias in the description.

Motion for Discovery and Disclosure of Any Records Used in Connection with the Jury Selection Process

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Sentencing Memorandum

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Sample Detention/Pre-Trial Electronic Monitoring Motion Incorporating Arguments on the Developmental Benefits of Play, Recreation, and Leisure

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Brief on the Merits of Amici Curiae Oregon Criminal Defense Lawyers Association and Oregon Justice Resource Center

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To read the opinion in this case, please click here.

Spears v. South Carolina

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This pleading addresses the reasonable Black person standard. Click here to read the opinion.

Motion to Allow Reasonable and Effective Voir Dire on Issues of Race, Implicit Bias and Attitudes, Experiences and Biases Concerning African Americans

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State v. Belcher Opinion

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This case holds that the superpredator theory constituted materially false, and, therefore, unreliable, evidence on which the sentencing court substantially relied and that the trial court abused its discretion in denying the defendant?s motion to correct an illegal sentence.

Memorandum for Disposition Hearing

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Oregon v. Arreola-Botello Opinion

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To read the Amici Brief submitted by Oregon Criminal Defense Lawyers Association and Oregon Justice Resource Center, please click here.

Spears v. South Carolina Opinion

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Click here to see the brief.

Brief on Behalf of Amicus Curiae in Support of Petitioner

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Brief for Leave of Appeal to Challenge Waiver to Adult Court

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Memorandum of Law in Support of Alternative Disposition Hearing Requested

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Commonwealth v. Evelyn Brief for the Defendant

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This brief addresses a reasonableness standard when considering race and age. Click here to see the defense reply brief and an amicus brief.

State v. Myers and Nyema, Brief of Proposed Amicus Curiae Kristin Henning

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Click here to read Myers and Nyema’s supplemental briefs.

Motion to Modify Detention Status

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Brief Objecting to the State’s Waiver to Adult Court

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Motion to Rescind Commitment and Request for Hearing

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Commonwealth v. Evelyn Reply Brief for the Defendant

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This brief addresses racial profiling. Click here to see the defense brief and an amicus brief.

State v. Myers Supplemental Brief

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Click here to read the amicus brief and Nyema’s supplemental briefs.

Brief on Behalf of Amici Curiae

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Appellant’s Application for Reconsideration

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Motion to Appeal Rejection of Pre-Trial Intervention Program

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Commonwealth v. Evelyn Amicus Brief in Support of the Defendant

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Click here to see the defense brief and the defense reply brief.