Justia Civil Rights Opinion Summaries

Thomas Eugene Creech, who has been on death row for over four decades for the 1981 murder of fellow inmate David Dale Jensen, filed a petition for a writ of mandamus. Creech alleged that the Ada County Prosecutor’s Office introduced fabricated or misleading evidence at his clemency hearing. He sought to recuse U.S. District Judge Amanda K. Brailsford from presiding over his underlying § 1983 suit, arguing that Judge Brailsford and Ada County Prosecutor Jan Bennetts are close friends, which could affect the judge's impartiality.The U.S. District Court for the District of Idaho denied Creech’s motion to preliminarily enjoin his execution, and the Ninth Circuit affirmed. Creech continued to litigate his § 1983 claim, alleging prosecutorial misconduct. He then moved to disqualify Judge Brailsford, citing her friendship with Bennetts. Judge Brailsford denied the recusal motion, stating that although she and Bennetts were close during their clerkship, they had since lost touch and a reasonable person would not question her impartiality.The United States Court of Appeals for the Ninth Circuit reviewed Creech’s petition for a writ of mandamus. The court found that the longstanding friendship between Judge Brailsford and Bennetts, combined with the allegations of prosecutorial misconduct involving Bennetts, could lead a reasonable person to question the judge’s impartiality. The court emphasized that public confidence in the judiciary requires that any appearance of bias be addressed promptly. Consequently, the Ninth Circuit granted the petition for a writ of mandamus and remanded the case for reassignment to a different judge. View "Creech v. United States District Court for the District of Idaho, Boise" on Justia Law

In February 2020, a police officer in Wauwatosa, Wisconsin, shot and killed a Black teenager, Alvin Cole. Following the incident, community members organized protests against police violence and racism. Anticipating unrest after the district attorney decided not to charge the officer, the mayor imposed a curfew. Plaintiffs, affected by the curfew and police conduct, filed constitutional and state law claims against the City of Wauwatosa and individual defendants.The United States District Court for the Eastern District of Wisconsin dismissed most claims, allowing only First Amendment and Driver’s Privacy Protection Act (DPPA) claims to proceed. The court later granted summary judgment for the defendants on the First Amendment claims, leaving only the DPPA claims for trial. The jury ultimately ruled in favor of the defendants on the DPPA claims.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the curfew was a permissible time, place, and manner restriction under the First Amendment. The court found that the curfew was content-neutral, served a significant government interest in public safety, was narrowly tailored, and left open ample alternative channels for communication. The court also upheld the dismissal of the plaintiffs' § 1983 claims against individual defendants, agreeing that the claims were inadequately pleaded and that the district court did not abuse its discretion in denying further amendments. Lastly, the court found no abuse of discretion in the district court’s response to a jury question regarding the definition of “personal information” under the DPPA. The judgment of the district court was affirmed. View "Knowlton v. City of Wauwatosa" on Justia Law

The case involves a probationer who was arrested during a traffic stop and subsequently charged with possession of cocaine with intent to distribute and unlawful possession of a firearm. During the traffic stop, a state trooper observed the vehicle speeding and making unsafe lane changes. Upon stopping the vehicle, the trooper noticed suspicious behavior from the back seat passenger and found drugs and a firearm in the vehicle. The probationer was found to have thrown a bag containing drugs to the back seat passenger as the vehicle was being pulled over.The Superior Court judge found the probationer in violation of his probation conditions, revoked his probation, and sentenced him to state prison. The probationer appealed, arguing that the evidence was insufficient to prove he possessed cocaine with intent to distribute and unlawfully possessed a firearm. He also claimed ineffective assistance of counsel for not moving to suppress the evidence on equal protection grounds, alleging racial animosity by the state trooper.The Supreme Judicial Court of Massachusetts reviewed the case and upheld the lower court's decision. The court found sufficient evidence to support the probation violation, including the possession and intent to distribute cocaine and the unlawful possession of a firearm. The court also rejected the claim of ineffective assistance of counsel, stating that the exclusionary rule does not generally apply to probation revocation proceedings and that the counsel's performance did not fall below the standard of an ordinary fallible lawyer.The court affirmed the revocation of probation and the denial of the motion for a new hearing. View "Commonwealth v. Gelin" on Justia Law

Lamonte Jackson-Gibson celebrated his birthday with friends, including his girlfriend, Toriel Dixon, in Detroit’s Greektown neighborhood. While listening to street musicians, Sergeant Reginald Beasley and other officers asked the group to move along. Jackson-Gibson questioned the order, leading to a verbal exchange and some physical pushing. Sgt. Beasley tased Jackson-Gibson in the back while he was embracing Dixon, and both were arrested. They were charged with obstructing or resisting a police officer, and Jackson-Gibson was also charged with disturbing the peace. A jury acquitted them of all charges.The United States District Court for the Eastern District of Michigan reviewed the case. Sgt. Beasley moved for summary judgment on the excessive-force claims, arguing for qualified immunity, but did not move for summary judgment on the wrongful-arrest claims. The district court granted summary judgment on Dixon’s excessive-force claim but denied it for Jackson-Gibson’s excessive-force claim. Sgt. Beasley’s motion to reconsider was also denied, leading to this interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Sgt. Beasley’s challenge to the wrongful-arrest claims for lack of jurisdiction, as he did not seek qualified immunity for those claims in the lower court. The court affirmed the district court’s denial of qualified immunity on Jackson-Gibson’s excessive-force claim. The court held that a reasonable jury could find that Sgt. Beasley’s use of a taser was objectively unreasonable, as Jackson-Gibson’s alleged crimes were not severe, he did not pose an immediate threat, and he was not actively resisting arrest. The court also held that the right to be free from excessive force when not actively resisting was clearly established by 2019. View "Jackson-Gibson v. Beasley" on Justia Law

The State of New York, through its Attorney General, sued the Niagara-Wheatfield Central School District, alleging that school officials failed to address repeated complaints of student-on-student sexual assault, harassment, and gender-based violence and bullying. The complaint detailed incidents involving four students who suffered from such misconduct and claimed that the school district ignored at least thirty similar incidents. The State argued that the school district's inaction affected not only the victims but also the broader school community, creating an unsafe environment.The United States District Court for the Western District of New York dismissed the case, concluding that the State lacked parens patriae standing. The court reasoned that the incidents were factually distinct and did not demonstrate a broader policy or practice of discrimination by the school district. Without such a policy or practice, the court held that the State could not show that the school district's conduct affected a substantial segment of the population, which is required for parens patriae standing.The United States Court of Appeals for the Second Circuit reviewed the case and reversed the district court's decision. The appellate court held that showing an injurious policy or practice is not necessary to satisfy the substantial-segment prong of the parens patriae standard. The court concluded that the State of New York had met its burden of pleading parens patriae standing at this stage of the litigation. The case was remanded for further proceedings consistent with the appellate court's opinion. View "New York v. Niagara-Wheatfield Central School District" on Justia Law

David Dajuanta Wallace was convicted of felony murder and a firearm offense related to the shooting death of Darius Bottoms. Wallace argued that the evidence was insufficient, that his due process rights were violated by being required to wear a leg iron and prison clothing during the trial, and that he received ineffective assistance of counsel.A Fulton County grand jury indicted Wallace and two co-defendants for various crimes, including felony murder and gang activity. Wallace pled guilty to some charges and went to trial on others. The jury found him guilty of felony murder and a firearm offense. The trial court sentenced him to life in prison with the possibility of parole for felony murder and an additional five years for the firearm charge. Wallace's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and found that the evidence was sufficient to support Wallace's convictions. The court held that the testimony of an accomplice was corroborated by other evidence, satisfying Georgia statutory law. Constitutionally, the evidence allowed the jury to find Wallace guilty as a party to the crimes rather than merely an accessory after the fact. The court also determined that any error related to Wallace wearing a leg iron was harmless beyond a reasonable doubt, given that the jury could not see the leg iron, Wallace used it strategically, and the strong evidence of his guilt.Regarding ineffective assistance of counsel, the court concluded that Wallace failed to show either deficiency or prejudice. The court affirmed Wallace's convictions and the trial court's rulings. View "WALLACE v. THE STATE" on Justia Law

In the early morning hours, Officer James Marshall observed Rodney Rucker sitting in a running car outside a hotel known for criminal activity. Marshall approached Rucker, who refused to identify himself or exit the vehicle. After additional officers arrived, they broke Rucker’s window, forcibly removed him, and arrested him. Rucker subsequently sued the officers under 42 U.S.C. § 1983, alleging unlawful seizure and arrest, First Amendment retaliation, excessive force, and bystander liability.The United States District Court for the Northern District of Mississippi denied the officers' motion for summary judgment on all claims, finding genuine disputes of material fact regarding the officers' reasonable suspicion, the alleged manufacturing of evidence, potential retaliation, and the reasonableness of the force used. The officers appealed, arguing that they were entitled to qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and reversed the district court’s decision. The appellate court found that the bodycam footage clearly showed that Officer Marshall had reasonable suspicion to stop and question Rucker based on the time, location, and Rucker’s behavior. The court also determined that Marshall had probable cause to arrest Rucker for failing to comply with lawful commands and for operating a vehicle without displaying a driver’s license. Additionally, the court held that the officers did not use excessive force, as Rucker’s repeated refusals to comply justified their actions. Consequently, the officers were entitled to qualified immunity on all claims, including the bystander liability claim against Officer Carter. The case was remanded for entry of summary judgment in favor of the officers. View "Rucker v. Marshall" on Justia Law

The plaintiff, Laurie DeVore, worked at the University of Kentucky from 1999 to 2022. She retired rather than comply with the University's COVID-19 test-or-vaccinate policy, which she claimed conflicted with her religious beliefs. DeVore filed a lawsuit alleging that the University violated Title VII of the Civil Rights Act of 1964 by failing to accommodate her religious beliefs. The University had denied her requests for a hybrid work schedule and religious exemptions from the testing policy, which required unvaccinated employees to undergo weekly COVID-19 testing.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the University. The court found that DeVore did not establish a prima facie case of religious discrimination because she failed to demonstrate that the University's policy conflicted with her sincerely held religious beliefs. DeVore appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court examined whether DeVore had a sincere religious belief that conflicted with the University's testing policy. DeVore's objections to the nasal PCR tests were initially based on invasiveness, manipulation, and coercion. However, the University offered alternative testing methods, such as oral swab and saliva tests, which DeVore also rejected without providing evidence of a religious conflict with these alternatives.The Sixth Circuit affirmed the district court's decision, holding that DeVore failed to establish a conflict between her religious beliefs and the University's testing policy. The court noted that DeVore's objections were largely based on personal moral codes and secular concerns rather than religious principles. Consequently, DeVore's Title VII claim did not succeed. View "DeVore v. University of Kentucky Board of Trustees" on Justia Law

Joe Baltas, a Connecticut state prisoner, was transferred to the Virginia Department of Corrections (VADOC) under the Interstate Corrections Compact. While at Red Onion State Prison (ROSP) in Virginia, Baltas alleges he was threatened by VADOC officials for filing a grievance and was later attacked by inmates, resulting in his placement in restrictive housing. He also claims that Connecticut Department of Corrections (CTDOC) officials failed to review his administrative segregation (Ad Seg) status as required, violating his due process rights under the Fourteenth Amendment. Additionally, he alleges violations of his First, Sixth, and Eighth Amendment rights due to his treatment at ROSP.The United States District Court for the District of Connecticut granted summary judgment in favor of the Defendants. The court found that CTDOC had adequately reviewed Baltas’s Ad Seg classification and dismissed his due process claim. It also dismissed his First, Sixth, and Eighth Amendment claims, concluding that Baltas failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the District Court’s ruling that CTDOC’s periodic reviews of Baltas’s Ad Seg classification satisfied due process requirements. However, it found that a genuine dispute of fact existed regarding whether VADOC’s administrative remedies were available to Baltas, making summary judgment inappropriate for his First, Sixth, and Eighth Amendment claims. The court vacated the summary judgment on these claims and remanded the case for further proceedings. The court also affirmed the dismissal of Baltas’s remaining claims in a concurrently issued summary order. View "Baltas v. Maiga" on Justia Law

Brothers Albert Ian Schweitzer and Shawn Schweitzer sought compensation for wrongful imprisonment under Hawai‘i Revised Statutes (HRS) Chapter 661B, which requires proving "actual innocence." They requested investigative materials from the Hawai‘i County Police Department (HPD) and the County of Hawai‘i Office of the Prosecuting Attorney (CHOPA) to support their claim. HPD and CHOPA refused, citing an ongoing investigation.In 2023, Ian Schweitzer filed a Hawai‘i Rules of Penal Procedure (HRPP) Rule 40 petition to vacate his conviction based on new DNA evidence pointing to another individual. The Circuit Court of the Third Circuit granted the petition, vacating Ian's conviction. Shawn Schweitzer subsequently moved to withdraw his guilty plea, which the court also granted. Both brothers then sought monetary compensation under HRS Chapter 661B, but the Attorney General stated that a finding of "actual innocence" was required.The Schweitzers filed a "Joint Petition for Relief Pursuant to HRS Chapter 661B" in their criminal proceedings, seeking a finding of actual innocence. The Circuit Court instructed them to file a motion to compel HPD to produce the investigative materials. The court granted the motion and directed the Schweitzers to prepare a subpoena. HPD filed a motion to quash the subpoena, which the court denied, leading HPD to file a writ of mandamus with the Supreme Court of Hawai‘i.The Supreme Court of Hawai‘i held that the Circuit Court had no discretion to act on the civil claims in the post-conviction proceeding and should have transferred the claims to a new civil case under HRPP Rule 40(c)(3). The court ordered the Circuit Court to quash the subpoena and transfer the Schweitzers' joint petition to a new civil proceeding, following the procedures prescribed by HRCP Rule 26 and HRS § 661B-2. The court clarified that Brady and UIPA do not apply to civil discovery and that there is no qualified law enforcement investigatory privilege in Hawai‘i. View "Hawai'i Police Department v. Kubota" on Justia Law