Justia Civil Rights Opinion Summaries

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Plaintiffs filed a class action suit on behalf of approximately 1.5 million Puerto Rican residents who are customers of Autoridad de Energia Electrica de Puerto Rico (PREPA), alleging that PREPA used a portion of its overall revenue to subsidize municipalities’ energy use. Plaintiffs claimed violations of the Takings Clause and their procedural due process rights because PREPA deprived them of their property interest in electricity and/or the funds they paid for electricity. The district court granted summary judgment for PREPA,concluding that Plaintiffs had not identified a valid property interest, that no taking had occurred, and that no valid procedural due process claim existed. The First Circuit affirmed on other grounds, holding that because Plaintiffs did not identify a valid property interest, they did not have standing to bring the takings and due process claims. View "Santiago-Ramos v. Autoridad de Energia Electrica de P.R." on Justia Law

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Plaintiff filed suit against defendants alleging that she was terminated for exercising her First Amendment right to free speech when she spoke to local leaders about what she saw as a "scam" occurring in the police department. The district court held that the officials had not shown entitlement to summary judgment of qualified immunity because, accepting plaintiff's facts as true and drawing all permissible factual inferences in her favor, she had shown that they had violated her clearly established constitutional rights. The court concluded that, under plaintiff's version of the facts, there was no doubt that under the prevailing decisions, plaintiff's speech was not made "pursuant to" her official duties as a patrol officer. Therefore, defendants failed to show entitlement to fire plaintiff or entitlement to qualified immunity under her version of the facts. Accordingly, the court affirmed the judgment. View "Ricciuti v. Gyzenis" on Justia Law

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Defendant was entered a guilty plea to charges of murder, domestic violence, and aggravated murder with capital specifications for the murders of his former girlfriend, their two-year-old son, and his girlfriend’s nine-year-old daughter. A three-judge panel unanimously sentenced Defendant to death of the aggravated murders of the two children and to fifteen years to life for his girlfriend’s murder. The Supreme Court affirmed Defendant’s convictions and sentence of death, holding (1) the panel did not err by failing sua sponte to order Defendant to undergo a competency evaluation; (2) the evidence presented during the plea hearing was sufficient to convict Defendant of the escaping detection specification attached to an aggravated murder, and defendant’s conviction of that specification was not against the manifest weight of the evidence; (3) defense counsel provided constitutionally effective assistance during the plea and mitigation hearings; (4) Defendant was not denied due process of law and a fair trial when the panel admitted and considered graphic photographs during the plea and mitigation hearings; and (5) Defendant’s death sentence was appropriate and proportionate. View "State v. Montgomery" on Justia Law

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After a jury trial, Appellant was found guilty of one count of first-degree murder of a peace officer, three counts of attempted first-degree murder of a peace officer, and one count of unauthorized possession of a firearm. The Supreme Court affirmed, holding (1) the district court did not violate Defendant’s right under the Minnesota Constitution to be tried by a jury of the county or district in which the alleged offense occurred; and (2) the district court did not commit prejudicial error by refusing to sever the first-degree murder charge from the other charges in Appellant’s case for the purpose of trial. View "State v. Fitch" on Justia Law

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After a jury trial, Appellant was found guilty of first-degree premeditated murder, two counts of first-degree intentional felony murder, and first-degree aggravated robbery. Appellant was sentenced to life without the possibility release for the murder conviction. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to suppress a confession he gave to police following his arrest, as the totality of the circumstances did not support Appellant’s argument that his confession to police was involuntary; and (2) the evidence was sufficient to support the jury’s verdict that Appellant committed premeditated murder. View "State v. Cox" on Justia Law

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After Manuel Diaz was shot by an Anaheim police officer, Diaz's estate and mother filed suit against the officer and the city, alleging federal civil rights violations. The jury returned the verdict in favor of defendants. The court concluded that the trial court erred in failing to bifurcate liability from compensatory damages where graphic and prejudicial evidence about the victim has little, and in large part no, relevance to the liability issue. Therefore, the court reversed and remanded to the district court with some guidance. First, the evidence of Diaz’s drug use and gang affiliation has marginal, if any, probative value as to damages, and none as to liability. On retrial, the district court should closely review this evidence under Federal Rules of Evidence 401 and 403, and should assure that such evidence is admitted only to the degree that the testimony is connected up with Ms. Huizar’s reaction to her son’s death. Second, if plaintiffs are willing to stipulate that Diaz was a gang member (which they claim they tried to do during trial), no expert testimony about gangs - such as gang activities, tattoos, or monikers - should be admitted. Third, while there is a “strong presumption that jurors follow instructions,” a limiting instruction may not sufficiently mitigate the prejudicial impact of evidence in all cases. And fourth, if the district court is going to sustain an objection and grant a motion to strike, merely saying “stricken” does not sufficiently inform the jury about the proper use of the evidence it just heard. Finally, the court concluded that the trial court did not err in ruling force was not excessive as a matter of law. View "Estate of Diaz v. City of Anaheim" on Justia Law

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Appellant drove her car through a red light, causing a collision with another car. A police detective applied for and was issued a warrant to search a sample of Appellant’s blood for “evidence of criminal vehicular operation.” The issuing judge found that probable cause existed for the issuance of the search. After Appellant’s blood was drawn, a toxicology report indicated that Appellant's blood contained a metabolite of THC and Alprazolam at the time of the accident. The State charged Appellant with criminal vehicular operation. Appellant filed a motion to suppress, arguing that the warrant did not provide probable cause for the police to test her blood for controlled substances. The district court granted Appellant’s motion, concluding that the blood sample was lawfully obtained under the warrant but that the subsequent testing of the blood sample for the presence of drugs was unlawful. The court of appeals reversed. The Supreme Court affirmed, holding (1) the facts alleged in the warrant application and supporting affidavit supported testing Appellant’s blood for controlled substances; and (2) the search warrant satisfied the particularity requirement in the Fourth Amendment. View "State v. Fawcett" on Justia Law

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Weldon, Fields, and Roth pooled $120 to buy heroin from Weldon’s drug dealer. Roth drove. Weldon got out of Roth’s car, walked to the dealer’s car, gave the dealer the $120, and returned with the heroin. At Roth’s home, Fields mixed the heroin with water, divided it, and injected it into the three of them. Roth died as a result. Fields was tried, but argued that injecting Roth was not distribution; she was acquitted. Weldon pleaded guilty to having distributed an illegal drug, resulting in a death, 21 U.S.C. 841(a)(1), (b)(1)(C). Because he agreed to cooperate in the prosecution of another person he received a prison sentence of only eight years. Three years later he moved to vacate his conviction on grounds that his lawyer had rendered ineffective assistance by persuading him to plead guilty. The Seventh Circuit vacated denial of the motion. Individuals who “simultaneously and jointly acquire possession of a drug for their own use, intending only to share it together,” are not distributors, “since both acquire possession from the outset and neither intends to distribute the drug to a third person.” Fields was acquitted and the defendants were participants in the same transaction. The insistence of Weldonʹs lawyer that a defense to the charge of distribution had no chance of success was constitutionally deficient. View "Weldon v. United States" on Justia Law

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For 60 years, a butcher shop operated on property in Black Earth that is zoned for commercial use, as a legal nonconforming use. In 2001, BEM purchased the property. After 2009, the volume and frequency of slaughter increased. By 2011, neighbors were complaining about increased traffic, trucks blocking the road, livestock noise, foul odors, improper storage of animal parts, and the presence of offal, blood, and animal waste in the streets. Steers escaped from the facility three times and had to be shot dead on Village streets. In 2013, the Village held several public meetings, and, because citations had no effect on BEM’s behavior, ordered BEM to propose an acceptable plan for relocating its slaughter activities. BEM did not relocate. After several delays, the Village threatened litigation. As a result of that threat, the USDA refused to guarantee a bank loan to BEM. BEM lost its financing, closed, and sued the Village and board members. The Seventh Circuit affirmed summary judgment for the defendants. Even if the threat of litigation could, itself, constitute a due process violation and were a sufficiently direct cause of BEM’s alleged deprivations, there is no evidence that the process accorded to BEM was inadequate. Procedural due process generally requires only “notice and an opportunity to be heard.” View "Black Earth Meat Mkt., LLC v. Village of Black Earth" on Justia Law

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Plaintiff filed suit against against her employers (Defendants), alleging that she had been subject to a sexually hostile or offensive work environment. The jury rendered a verdict in favor of Plaintiff, finding that Defendants were liable for $40,000 in compensatory damages and $500,000 in punitive damages. The superior court judge granted Defendant’s motion for judgment notwithstanding the verdict in part, allowing the motion as to the award of punitive damages but denying it with respect to the award of compensatory damages. Both parties appealed. The Supreme Judicial Court affirmed the award of compensatory damages, reversed the judge’s order granting judgment notwithstanding the verdict as to the punitive damages award, and reinstated the jury’s verdict, holding that, based on the evidence, the jury could have found that Defendants failed to take adequate remedial measures after being put on notice of a sexually hostile or offensive work environment and that the failure was egregious or outrageous. Remanded for calculation of Plaintiff’s attorney’s fees and consideration of Defendant’s motion for remittitur as to the punitive damages award. View "Gyulakian v. Lexus of Watertown, Inc." on Justia Law