Justia Civil Rights Opinion Summaries

Thirteen Black male defendants were tried together in the Central District of Illinois on charges related to alleged gang activities, including drug trafficking and violent crimes. During jury selection, the government used peremptory challenges to remove two prospective jurors: Juror 26, a Black man employed by the Peoria Housing Authority, and Juror 58, a Hispanic woman who taught at a local charter school. The defendants objected, contending that the government impermissibly struck the only two non-white members of the jury panel.The United States District Court for the Central District of Illinois initially overruled the Batson objections at step one, finding the defendants failed to establish purposeful discrimination. On appeal, the United States Court of Appeals for the Seventh Circuit determined that the district court had misapplied the Batson framework, particularly by imposing too high a burden at step one and by failing to make adequate findings at step three. The appellate court remanded the case for the district court to properly apply all three Batson steps.Upon remand, the district court reconsidered the Batson challenges, conducted a new analysis of all three steps, and found that while the defendants made a prima facie case as to Juror 26, the government provided credible, race-neutral reasons for striking both Juror 26 and Juror 58. The court concluded there was no purposeful discrimination.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s findings for clear error and found none. The appellate court affirmed the district court’s conclusion that the government’s peremptory strikes were not motivated by racial discrimination, thus rejecting the defendants’ Batson claims and affirming the judgment. View "USA v Watkins" on Justia Law

A Milwaukee County Sheriff’s deputy, while on duty and driving his unmarked vehicle, caused a fatal collision after running a red light at a controlled intersection. The deputy failed to notice the light change because he was distracted—looking at either his cellphone or his dashboard computer—for over 15 seconds as he approached the intersection. He was traveling at or just below the speed limit at the time. The victim, Ceaser Stinson, was lawfully passing through the intersection when his vehicle was struck and he was killed. Investigations confirmed the deputy’s inattention as the cause of the accident.Following the crash, Stinson’s estate filed a lawsuit in state court against the deputy, Milwaukee County, and the county’s insurer, alleging, among other claims, a violation of Stinson’s substantive due process rights under 42 U.S.C. § 1983. After removal to the United States District Court for the Eastern District of Wisconsin, the court dismissed some claims but permitted the estate’s § 1983 claim against the deputy to proceed. The defendants moved for summary judgment, arguing that the deputy’s conduct did not meet the threshold for a constitutional violation and that he was entitled to qualified immunity. The district judge denied the motion, concluding that a jury should decide whether the conduct was egregious enough to violate due process and deferred ruling on qualified immunity until after a jury verdict.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the estate failed to show the deputy acted with deliberate indifference to a known and imminent harm, as required for a substantive due process violation. The court further held that it was not clearly established that distracted driving by a law enforcement officer violates due process. Accordingly, the court reversed the district court’s judgment and ordered entry of judgment in favor of the deputy, finding him entitled to qualified immunity. View "Estate of Stinson v. Streicher" on Justia Law

After reports and investigations of sexual abuse allegations against a father, the State’s Department of Human Services (DHS) petitioned for foster custody of his children. The family court consolidated the cases, and in September 2024, it issued orders granting DHS foster custody and incorporating a Service Plan that required the father to participate in sex abuse treatment. Importantly, the plan mandated that he “acknowledge and take responsibility for the sexual abuse to his victims” as a condition of successful completion.The father appealed these orders to the Intermediate Court of Appeals of Hawai‘i (ICA), which affirmed the family court's decision. Due to complications with his legal representation, the father’s application for writ of certiorari to the Supreme Court of Hawai‘i was filed late, but the Supreme Court agreed to consider the merits, recognizing his constitutional right to counsel in parental rights termination proceedings.The Supreme Court of Hawai‘i reviewed whether the State can require a parent, as part of mandated rehabilitation therapy in child custody proceedings, to make incriminating disclosures. The court held that under Article I, Section 10 of the Hawai‘i Constitution, the State may not require a parent to admit to criminal misconduct as a condition of completing court-ordered therapy, as this violates the privilege against self-incrimination. However, the court clarified that if a parent’s silence or refusal to admit abuse hinders effective therapy, the court may consider that as a factor in custody determinations without violating the constitutional privilege. The court vacated the lower courts’ orders to the extent they required the father to admit to sexual abuse, and remanded for further proceedings consistent with its opinion. The lower courts’ orders were otherwise affirmed. View "In re: T.J." on Justia Law

A woman named Melissa asked a police officer to accompany her to a residence so she could retrieve her belongings. She told the officer, Chance Avery, that Christopher, who was at the residence, was drunk, mean, had threatened her, and had been drinking. When they arrived, Melissa entered the home and began collecting her things while Avery waited in the hallway. Christopher, holding a baseball bat at his side, entered the house, loudly asking where the police were. Avery immediately drew his gun and ordered Christopher to drop the bat. Christopher said he would comply, but after about 11 seconds and after taking a single step in Avery’s general direction without raising or swinging the bat, Avery shot Christopher three times, killing him.The special administrator of Christopher’s estate, Vision Bank, filed a lawsuit in the United States District Court for the Western District of Oklahoma, asserting that Avery used excessive force in violation of the Fourth Amendment under 42 U.S.C. § 1983. Avery sought summary judgment, claiming qualified immunity, but the district court denied his motion. The court found that, based on the facts a reasonable jury could conclude, Avery’s use of deadly force was objectively unreasonable and violated clearly established law.The United States Court of Appeals for the Tenth Circuit reviewed the district court’s denial of qualified immunity. The appellate court affirmed the district court’s decision, holding that, under the facts a reasonable jury could find, Avery’s use of force was objectively unreasonable and violated Christopher’s clearly established Fourth Amendment rights. The court found that prior Tenth Circuit precedent made it clear that an officer may not use deadly force against a person holding a bat but making no hostile or aggressive motions. Therefore, Avery was not entitled to qualified immunity. View "Vision Bank v. Avery" on Justia Law

Two children, whose parents divorced in Missouri, were involved in a custody dispute. After the parents agreed to a custody arrangement, the children refused to leave the courthouse with their mother. Judge Eric Eighmy intervened, escorting the children to a conference room and later to the juvenile division, where repeated threats of foster care failed to persuade them. Ultimately, Judge Eighmy ordered a juvenile officer to lock the children in holding cells for twenty to forty minutes, after which they agreed to leave with their mother.The children’s father brought suit in the United States District Court for the Western District of Missouri, alleging violations of their Fourth Amendment rights under 42 U.S.C. § 1983. Judge Eighmy’s claim for judicial immunity was denied both at the motion-to-dismiss and summary-judgment stages, and the Eighth Circuit previously affirmed that denial in Rockett ex rel. K.R. v. Eighmy, 71 F.4th 665 (8th Cir. 2023). After a trial, the jury found for the children, awarding $5,000 each in damages. The district court resubmitted the damages issue for clarification and ultimately upheld the jury’s award, also granting $326,637.22 in attorney fees.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo and affirmed the district court’s judgment. The court held that Judge Eighmy’s actions constituted an unreasonable seizure in violation of clearly established Fourth Amendment rights. The court also dismissed the appeal regarding judicial immunity, finding it unreviewable due to procedural forfeiture. The Eighth Circuit affirmed the damages and attorney fees awards, finding no abuse of discretion by the district court. The disposition was to dismiss the appeal in part and affirm the district court’s judgments. View "Rockett v. Eighmy" on Justia Law

Christopher Davis, a Black man, was convicted in 2004 of being an ex-felon in possession of a firearm and unlawfully possessing ammunition after police found a loaded handgun and bullets in his apartment. The jury convicted him on those charges, and the trial court found true all 10 prior strike convictions and two prior prison terms. He was sentenced to two years plus 25 years to life under California’s three strikes law. In November 2023, the court struck the two prior prison terms, imposed a 25-year-to-life sentence, and scheduled further resentencing.Afterward, Davis filed a motion with the Superior Court of Riverside County in August 2024 seeking discovery under the Racial Justice Act (RJA), arguing he may have received harsher charging or sentencing than similarly situated non-Black defendants. He requested records of comparable cases in Riverside County, including defendants' racial backgrounds and sentencing outcomes. The People objected, arguing Davis’s evidence was insufficient and that the RJA does not apply to third-strike sentences. On April 28, 2025, the Superior Court granted Davis’s motion for discovery, finding he met the minimal burden for such a request.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. It held Davis failed to present a plausible factual foundation, based on specific facts, that a violation of the RJA could or might have occurred, because the supposed comparator cases were not sufficiently similar and the statistical evidence was unreliable, irrelevant, and lacking expert explanation. The Court also concluded the data Davis presented failed to demonstrate racial disparity specific to his circumstances. The Court granted the People’s petition, directing the superior court to vacate its order granting discovery and to enter an order denying the motion. View "People v. Super. Ct." on Justia Law

A former Michigan Department of Corrections prisoner with asthma and an alleged allergy to dogs experienced allergic reactions while incarcerated at multiple facilities that housed dogs for training purposes. He reported symptoms such as asthma attacks and respiratory infections to prison officials, who provided prescribed treatments but did not confirm a specific dog allergy. After pursuing the prison’s grievance process, he was moved within the facility but still encountered dogs during required programming. Subsequently, he requested an ADA accommodation to be housed away from dogs, but this was denied due to lack of medical documentation. He later filed suit, alleging violations of the Eighth Amendment, the ADA, the Rehabilitation Act, and state laws.The United States District Court for the Western District of Michigan granted summary judgment in favor of the defendants. The court found that prison officials were not deliberately indifferent to his medical needs under the Eighth Amendment, as they consulted medical staff who did not recommend a transfer based on his condition. For the ADA and Rehabilitation Act claims, the court determined that inadequate medical treatment was not actionable under those statutes and that the plaintiff had not demonstrated denial of prison services or programs due to his disability. The court also declined to exercise supplemental jurisdiction over the state-law claims.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The appellate court affirmed the grant of summary judgment, holding that the prison counselor was entitled to qualified immunity because no clearly established law required the transfer of prisoners with asthma to facilities without dog programs. The court also found that the plaintiff failed to provide sufficient medical documentation to support the necessity of the requested accommodation under the ADA and Rehabilitation Act and did not establish discriminatory animus. The district court’s refusal to exercise supplemental jurisdiction over state-law claims was also affirmed. View "Miles-El v. Michigan" on Justia Law

The case concerns a defendant convicted in 2014 of first degree murder and possession of a firearm by a felon, along with firearm and gang enhancements, following the fatal shooting of a victim in an apartment complex parking lot. The defendant, a self-admitted member of the Grape Street gang, initially denied involvement but later admitted to shooting the victim after alleging prior conflicts. Evidence contradicted some of his claims, including the absence of a weapon allegedly belonging to the victim and prison records showing no prior shared incarceration. After resentencing proceedings reduced part of his sentence due to legislative changes, the defendant repeatedly sought relief under the California Racial Justice Act (CRJA), alleging racial bias and discriminatory charging and sentencing.Following conviction in San Bernardino County Superior Court, the defendant filed several habeas corpus petitions and CRJA motions. He argued that a juror exhibited racial bias, that a prosecutor made racially discriminatory statements, and cited statistical disparities in sentence enhancements for Black defendants. Each petition was denied by the Superior Court, and appellate review of one denial was dismissed as no appeal lies from such an order. Subsequent motions, including those based on new facts and law, were also denied. The defendant was resentenced to a total indeterminate term of 50 years to life, and a concurrent determinate term of two years, with gang enhancements struck.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the trial court’s denial of the CRJA motion. It held that the defendant had not set forth a prima facie case under the CRJA. Specifically, the evidence provided did not establish juror or prosecutorial bias or discriminatory charging, nor did the statistical data or other evidence demonstrate that similarly situated nonminority defendants were treated more favorably. The trial court’s orders were affirmed. View "People v. Williams" on Justia Law

A pretrial detainee died of a drug overdose after approximately seventeen hours in a county jail. The plaintiff, acting as the decedent’s personal representative, alleged that jail staff failed to provide adequate medical care despite clear signs of a drug-related medical emergency. Surveillance footage and the complaint detailed that the detainee was visibly impaired, periodically unconscious, and left unmonitored for extended periods. Staff placed him in a holding cell for about nine hours, during which he was not observed or treated, and he later died from acute intoxication involving multiple substances.The United States District Court for the Eastern District of Tennessee reviewed the case at the pleading stage. The plaintiff brought claims under 42 U.S.C. § 1983 against Knox County, alleging several theories of municipal liability, including failure to train staff, inadequate medical screening, underfunding, and overcrowding. The district court granted the County’s motion to dismiss all municipal liability claims and declined to exercise supplemental jurisdiction over state law claims. The plaintiff appealed, challenging only the dismissal of municipal liability claims against the County.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit held that the plaintiff plausibly alleged a failure-to-train claim against the County, finding that the complaint and surveillance video supported a reasonable inference that jail staff were not adequately trained to recognize and respond to drug-related medical emergencies. The court reversed the district court’s dismissal as to the failure-to-train claim, allowing it to proceed. However, it affirmed the dismissal of other municipal liability claims, concluding those theories were not sufficiently supported by factual allegations. View "Byrum v. Knox County" on Justia Law

Late at night, as Allison Beaver left work at a Taco Bell in Bristol, Tennessee, Charles Mixon confronted her in the parking lot with a handgun, forced her into her car, and ordered her to undress. When Mixon became distracted while driving, Beaver escaped and called the police. Mixon fled across the state line into Virginia, where he confessed to his stepfather, admitting he had stolen his stepfather’s gun for the carjacking. Upon refusing to return the firearm, Mixon was apprehended by police as he crossed back into Tennessee, in possession of the stolen gun.The United States District Court for the Eastern District of Tennessee heard the case against Mixon, who was indicted for carjacking, using and brandishing a firearm in furtherance of a crime, being a felon in possession of a firearm with at least three qualifying convictions under the Armed Career Criminal Act (ACCA), and possessing a stolen firearm. Mixon moved to dismiss the indictment, arguing the statutes exceeded Congress’s Commerce Clause power and that his Texas burglary convictions did not qualify as “violent felonies” under ACCA. The district court denied these motions and allowed evidence regarding his prior offenses, despite Mixon’s offer to stipulate to certain facts.On appeal, the United States Court of Appeals for the Sixth Circuit addressed Mixon’s Commerce Clause challenge, his argument that his Texas burglaries were not ACCA predicates, and his objection to the admission of prior crime evidence. The Sixth Circuit held that the statutes at issue were valid exercises of congressional power under prevailing precedent, that Texas burglary under Penal Code § 30.02(a) qualifies as generic burglary for ACCA purposes, and that the district court did not abuse its discretion in admitting evidence of Mixon’s prior robbery. Accordingly, the court affirmed Mixon’s convictions and sentence. View "United States v. Mixon" on Justia Law