Justia Civil Rights Opinion Summaries

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Robert Montano, a pretrial detainee in the county jail, died of acute renal failure after approximately four-and-one-half days’ detention in a glass-walled observation cell in the jail’s infirmary. This 42 U.S.C. 1983 action was filed against the county on three theories of liability: unconstitutional condition of confinement relative to a county custom for holding incoherent pretrial detainees; episodic acts or omissions; and unconstitutional condition of confinement relative to a county custom of failing to meet basic human needs. In regards to the unconstitutional-condition-of-confinement claim, the court concluded that the district court properly denied the county JMOL against the jury’s finding the condition. In this case, trial testimony adequately established the protocol exercised in Mr. Montano’s experience was standard jail practice; the record demonstrates his experience was not a mere “isolated example”, but was, instead, a “pervasive pattern of serious deficiencies in providing for his basic human needs”. The court concluded that the district court properly denied the county's Rule 50(b) motion regarding the $1.5 million awarded for pain Mr. Montano suffered. Because section 1983 liability and damages are upheld, the court concluded that plaintiffs remain the prevailing parties and are entitled to those fees and costs. Because the constitutional deprivation is well established and the causal link was admitted at trial, satisfying Texas’ causation standard, the court concluded that the standard for wrongful-death damages is satisfied. Therefore, JMOL was improperly awarded to the county on wrongful-death damages. Accordingly, the court affirmed in part, vacated in part, and remanded. View "Montano v. Orange County, Texas" on Justia Law

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Haywood, an inmate at Illinois’s Shawnee Correctional Center, accused a teacher of attacking him. Guards charged him with making false statements. A disciplinary panel found him guilty, ordered him transferred to segregation for two months, and revoked one month of good‐time credit. He was subsequently transferred to a different prison and filed suit under 42 U.S.C. 1983, alleging First Amendment violations and that his conditions of confinement in segregation were cruel and unusual, violating the Eighth Amendment. The district court rejected both claims, dismissing the First Amendment claim because the disciplinary panel’s decision, which affected the duration of Haywood’s confinement, had not been set aside on collateral review or by executive clemency. The court cited Supreme Court holdings that section 1983 cannot be used to seek damages when relief necessarily implies the invalidity of a criminal conviction or prison discipline that remains in force. The Seventh Circuit affirmed with respect to the First Amendment theory and reversed with respect to the Eighth Amendment theory, remanding for consideration under the deliberate indifference standard.The warden had actual knowledge of the unusually harsh weather, had been apprised of the specific problem with Haywood’s cell (the windows would not shut), and had toured the segregation unit. View "Haywood v. Hathaway" on Justia Law

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After a jury trial, Appellant was convicted of conspiracy to deliver a controlled substance. The district court sentenced Appellant to not less than four years nor more than eight years in prison. Appellant appealed, claiming that he received ineffective assistance of counsel because “a skilled criminal defense advocate would likely be able to secure a more favorable agreement than was obtained in his current sentence.” The Supreme Court affirmed, holding that Appellant failed to establish that he was prejudiced by counsel’s alleged deficient performance, and therefore, it was unnecessary to address the deficiency prong of the ineffectiveness standard. View "McNaughton v. State" on Justia Law

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Defendant was convicted of drunk driving, possession of marijuana, and possession of drug paraphernalia. The court of appeals reversed the circuit court’s order denying Defnednat’s motion to suppress, concluding that the warrantless entry by a deputy with the sheriff’s department into Defendant’s garage was not justified by the exigent circumstance of the deputy’s “hot pursuit” of a fleeing suspect who had committed jailable offenses. The Supreme Court reversed, holding that the deputy’s warrantless entry into Defendant’s garage and subsequent arrest of Defendant were constitutional because they were justified by the exigent circumstance of hot pursuit of a fleeing suspect who had committed jailable offenses. View "State v. Weber" on Justia Law

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Defendant was charged with felony possession. Defendant filed a motion to suppress, arguing that the police violated the Fourth Amendment and Article I, Section 11 of the Indiana Constitution when they opened his car door “to check on [Defendant’s] welfare.” The trial court denied the motion and, after a bench trial, convicted Defendant of misdemeanor possession of cocaine. The court of appeals affirmed, concluding that the police’s act of opening Defendant’s door was constitutionally permissible as a reasonable community caretaking function. The Supreme Court granted transfer, thereby vacating the decision of the court of appeals, and affirmed, holding that the police’s warrantless search of Defendant was constitutionally permissible, as the officer had an objectively reasonable basis to open the door and check on Defendant’s well-being. View "Cruz-Salazar v. State" on Justia Law

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Defendant was charged with operating a vehicle while intoxicated in a manner that endangers a person and operating a vehicle with a blood alcohol concentration of at least 0.08. Defendant filed a motion to suppress, claiming that the warrantless traffic stop that led to her arrest was constitutionally invalid. The trial court denied the motion. The court of appeals reversed, holding that the police exceeded their authority under the Fourth Amendment in stopping Defendant’s vehicle out of an alleged concern for Defendant’s medical state. The Supreme Court granted transfer, thus vacating the court of appeals opinion, and reversed the trial court’s denial of Defendant’s motion to suppress, holding that the State failed to carry its burden of showing that an exception to the warrant requirement of the Fourth Amendment justified the stop. View "Osborne v. State" on Justia Law

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After a jury trial, Defendant was convicted of attempted second-degree murder and other offenses. Defendant appealed his conviction of attempted second-degree murder, challenging the trial judge’s finding that defense counsel’s explanations for striking jurors were a pretext for racial discrimination. The Court of Special Appeals affirmed. The Court of Appeals reversed, holding (1) the trial judge’s finding that defense counsel’s peremptory challenges were a pretext for racial discrimination was clearly erroneous; and (2) the evidence was insufficient for a rational trier of fact to find beyond a reasonable doubt specific intent for the crime of attempted second-degree murder. Remanded for a new trial as to all remaining counts except for the count charging attempted second-degree murder. View "Spencer v. State" on Justia Law

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After a jury trial, Defendant was found guilty of six counts of gross sexual assault and six counts of unlawful sexual contact. Defendant appealed, arguing, inter alia, that the trial court erred in denying his motion to suppress evidence of inculpatory statements he made during a police interview. The Supreme Court vacated the judgment of conviction, holding that the totality of the circumstances rendered Defendant’s incriminating statements involuntary as a matter of law, and therefore, the suppression court erred when it denied Defendant’s motion to suppress the evidence of those incriminating statements. Remanded for a new trial. View "Maine v. Hunt" on Justia Law

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Plaintiff filed suit under 42 U.S.C. 1983, alleging that officers used excessive force in violation of her constitutional rights. The district court granted summary judgment in favor of Corporal Kisela, concluding that his actions were reasonable and that he was entitled to qualified immunity. The court concluded that, when viewing the facts in the light most favorable to plaintiff, the record does not support Corporal Kisela’s perception of an immediate threat. In this case, plaintiff did not raise the knife she was holding and did not make any aggressive or threatening actions toward another woman, Sharon Chadwick. Ms. Chadwick describes plaintiff as having been composed and non-threatening immediately prior to the shooting. The court concluded that material questions of fact, such as the severity of the threat, the adequacy of police warnings, and the potential for less intrusive means are plainly in dispute. Therefore, Corporal Kisela was not entitled to summary judgment with respect to the reasonableness of his actions. The court also concluded that Corporal Kisela is not entitled to qualified immunity where the facts present the police shooting a woman who was committing no crime and holding a kitchen knife. While the woman with the knife may have been acting erratically, was approaching a third party, and did not immediately comply with orders to drop the knife, a rational jury—accepting the facts in the light most favorable to plaintiff—could find that she had a constitutional right to walk down her driveway holding a knife without being shot. Accordingly, the court reversed and remanded. View "Hughes v. Kisela" on Justia Law

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Plaintiff filed suit against Major Wheeler and others, alleging, inter alia, a claim under 42 U.S.C. 1983 for violation of his First Amendment rights and a claim under Georgia law for defamation. After plaintiff reported constitutional violations by his fellow officers, Major Wheeler issued a county-wide alert to all law-enforcement officers, picturing plaintiff, warning that he was a “loose cannon” who presented a “danger to any [law-enforcement officer] in Douglas County,” and directing officers to “act accordingly.” The district court denied Wheeler's motion for qualified immunity and official immunity on the defamation claim. The court concluded that plaintiff's allegations allow for the reasonable inferences that the Police Department communicated with the Sheriff’s Department about plaintiff's complaints prior to Wheeler’s issuance of the be-on-the-lookout advisory (BOLO), that the Sheriff’s Office and Wheeler knew about the termination-appeal hearing, and that Wheeler issued the BOLO at least in part in retaliation for plaintiff's complaints. Therefore, the court concluded that plaintiff sufficiently alleged that Wheeler violated plaintiff's First Amendment rights when he issued the BOLO and the court affirmed the denial of qualified immunity. The court also concluded that plaintiff's constitutional right to be free from retaliation that imperiled his life was clearly established at the time that Wheeler issued the BOLO. The allegations satisfy the showing of a deliberate intention to do wrong—that is, actual malice. Therefore, the court affirmed the district court's denial of official immunity. View "Bailey v. Major Tommy Wheeler" on Justia Law