This project has compiled model motions that criminal defense attorneys can adapt and use to request information about law enforcement’s use of digital surveillance technologies, ranging from facial recognition to license plate readers to other forms of location tracking tech.
Motions and Briefs
Fingerprint Discovery Checklist
Items to request in discovery. A Word document will be downloaded to your download folder when you click here.
NACDL 4AC’s Omnibus Tech Discovery Checklist
This discovery list serves as an all-in-one, cover-your-bases initial discovery checklist for many of the most commonly used categories of technology that you will see in your cases.
Affidavit of Jennifer Carroll, PhD, MPH, MA
Addresses public health consequences of laws creating criminal liability for accidental drug overdose and provides research supporting the following conclusions:
Appellant Reply Brief in State v. Anderson
Addresses defendant’s motion to dismiss where evidence on causation was insufficient, failure to instruct the jury on intervening acts of others, failure to instruct the jury on lesser included offense of involuntary manslaughter when the evidence of malice was in conflict, and court’s failure to intervene in state’s closing argument. Reply Brief filed in June …
Appellant Brief in State v. Anderson
Appellant’s Brief addressing trial court’s denial of defendant’s motion to dismiss where the state did not prove the defendant’s actions proximately caused the decedents’ deaths and another individual’s actions were a superseding cause of the decedents’ deaths which broke the chain of causation. Also addresses trial court’s failure to instruct on whether intentional acts by …
Appellant Brief in State v. McCrorey
Addresses complex chain of causation, proximate cause, identify of the controlled substance, and cause of death. Brief filed in Aug. 2023 in 2020 case.
Notice of Objection
Sample notice of objection to the admission of lab report without the testimony of the chemical analyst
Bridges Amicus Brief
Filed by the Innocent Network in support of the defendant.