Justia Civil Rights Opinion Summaries

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Plaintiff-appellant Virginia Arnold appealed the grant of summary judgment in favor of her employer, defendant-respondent Dignity Health (Dignity) and other individually named defendants. Arnold was employed as a medical assistant. She alleged defendants engaged in discrimination, harassment, and retaliation based on her age and her association with her African-American coworkers, including by terminating her employment in violation of the Fair Employment and Housing Act (FEHA). On summary judgment, the trial court concluded defendants provided evidence of legitimate reasons for plaintiff’s termination and, in rebuttal, plaintiff failed to offer any evidence that defendants’ actions were discriminatory, harassing, or retaliatory. The Court of Appeal concurred with the trial court's findings and affirmed summary judgment. View "Arnold v. Dignity Health" on Justia Law

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Wofford was found guilty of a 1993 murder in a Michigan court following the removal and replacement of a juror. While that juror was holding out against conviction at the time, the judge removed her for misconduct: she had violated his instructions not to discuss the case with anyone other than her fellow jurors by hiring a lawyer to address the court about tensions in the jury room. The Michigan Court of Appeals affirmed Wofford’s conviction under a state precedent on juror removal.A federal district court granted Wofford’s petition for a writ of habeas corpus, finding that decision not entitled to deference under the Anti-Terrorism and Effective Death Penalty Act, 28 U.S.C. 2254, because the Michigan court had overlooked Wofford’s Sixth Amendment claims and the removal of the juror violated Wofford’s Sixth Amendment rights.The Sixth Circuit reversed. The 2020 Supreme Court decision, “Ramos,” held that the right not to have a juror removed due to the juror’s opinions on the merits of the case is contained in the Sixth Amendment’s guarantee of a “trial by an impartial jury.” Michigan did not overlook Wofford’s Sixth Amendment claims. While the juror was a holdout, she was not removed for this reason, but because of her misconduct. The Michigan court was free to require a showing of an actual constitutional violation and clearly, if implicitly, did so. View "Wofford v. Woods" on Justia Law

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Adopted in 2019, Ohio Revised Code 1349.05(B) states: No health care practitioner, with the intent to obtain professional employment for the health care practitioner, shall directly contact in person, by telephone, or by electronic means any party to a motor vehicle accident, any victim of a crime, or any witness to a motor vehicle accident or crime until thirty days after the date of the motor vehicle accident or crime. Any communication to obtain professional employment shall be sent via the United States postal service. Subsection (C) provides the same restrictions but with regard to the agents of health care practitioners. The plaintiffs provide chiropractic services; one plaintiff is a referral service that identifies and contacts prospective patients for health care providers. The plaintiffs claim that they “all rely upon advertising and marketing techniques that permit prompt contact with victims of motor vehicle and pedestrian accidents.” They alleged that the statute violates their constitutional rights to free speech and equal protection. The Sixth Circuit affirmed the district court in denying relief. The plaintiffs failed to show a substantial likelihood of succeeding on the merits of their free speech and equal protection claims; “strong” precedents foreclosed the plaintiffs’ challenges. View "First Choice Chiropractic, LLC v. DeWine" on Justia Law

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Plaintiffs filed suit against the Government, alleging that the male-only military draft unlawfully discriminates based on sex. The Military Selective Service Act requires essentially all male citizens and immigrants between the ages of eighteen and twenty-six to register with the Selective Service System. The district court granted plaintiffs declaratory judgment and held that requiring only men to register for the draft violated their Fifth Amendment rights.The Fifth Circuit reversed, holding that the district court's judgment directly contradicts the Supreme Court's holding in Rostker v. Goldberg, 453 U.S. 57, 78–79 (1981). In Rostker, the Supreme Court held that the male-only Selective Service registration requirement did not offend due process where women at the time were barred from combat. The court explained that here, as in State Oil Co. v. Khan, 522 U.S. 3, 22 (1997), the factual underpinning of the controlling Supreme Court decision has changed, but that does not grant a court of appeals license to disregard or overrule that precedent. Accordingly, the court dismissed the case. View "National Coalition for Men v. Selective Service System" on Justia Law

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The Supreme Court affirmed the judgments of the of the trial court convicting Defendants of first degree murder and other crimes and sentencing both defendants to death, holding that no prejudice resulted from any error of the trial court.Separate juries convicted Daniel Silveria and John Travis of first degree murder, second degree robbery, and second degree burglary. After retrials, a single penalty jury returned death verdicts. The Supreme Court affirmed, holding (1) during the guilt phase, the trial court did not err in denying Travis's motion to suppress or in instructing the jury on first degree murder; and (2) during the joint penalty retrial, there was no abuse of discretion in denying Defendants' severance motions, the trial court did not wrongfully excuse for cause prospective jurors, the trial court did not err in admitting portions of Silveria's first penalty phase testimony, any error in placing conditions on proffered testimony by Travis's trial counsel was harmless, and any other assumed or actual error was not prejudicial. View "People v. Silveria" on Justia Law

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The Supreme Court affirmed Defendant's convictions for four counts of first degree murder and other crimes and sentence of death, holding that, considering any actual or assumed errors altogether, their cumulative effect did not warrant reversal of Defendant's convictions or sentence.Specifically, the Supreme Court held (1) assuming that the trial court erred by using an unsworn, uncertified interpreter during the preliminary hearing and to interpret a victim's outburst, there was no prejudice; (2) sufficient evidence supported the theory of felony murder for two murders, and even assuming there was no sufficient evidence, the first degree murder verdicts would still be upheld; (3) there was assumed or found error during trial regarding difficulties that made it difficult to hearing the court proceedings, the accuracy of interpreters, and other issues, but there was no prejudice; and (4) none of the assumed or actual errors, considered either individually or collectively, warranted reversal of Defendant's convictions or sentence. View "People v. Suarez" on Justia Law

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The Supreme Judicial Court vacated the judgment of the trial court convicting Defendant for failure to comply with the Sex Offender Registration and Notification Act of 1999 (SORNA of 1999), Me. Rev. Stat. 34-A, 11227(2), holding that, due to inadequate representation by Defendant's trial counsel, the court committed obvious error by not addressing the constitutionality of SORNA of 1999, as retroactively applied to Defendant.In 1990, Defendant was convicted of four counts of unlawful sexual contact, and in 1992, he was convicted of gross sexual assault. Neither offense required Defendant to register as a sex offender. After the Legislature enacted SORNA of 1999, Defendant 's two convictions became subject to SORNA of 1999. In 2018, Defendant was found guilty of failure to comply with a duty under SORNA of 1999. On appeal, Defendant argued that the retroactive application of SORNA of 1999 to require him to register for life violated the state and federal constitutional prohibitions against ex post facto laws. The Supreme Judicial Court agreed, holding that it could not be said beyond a reasonable doubt that the retroactive application of SORNA of 1999 to Defendant's 1990 and 1992 convictions did not affect his substantial rights by virtue of a punitive alteration of his original sentences. View "State v. Proctor" on Justia Law

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The Supreme Court vacated this Court's denial of Defendant's motion to supplement and remanded the case to the court of appeals to consider the issue of whether Defendant knowingly, intelligently, and voluntarily waived his right to trial counsel.Defendant filed a motion to supplement the record with the transcript of a hearing, during which Defendant signed a waiver of his right to trial counsel. The transcript had not been included in the record considered by the court of appeals, which overruled Defendant's argument that he did not knowingly, intelligently, and voluntarily waive his right to counsel. The Supreme Court denied the motion to supplement, but, on further consideration, vacated the denial and granted the motion to supplement the record with the transcript of the hearing. Because the court of appeals was not privy to the complete record of the hearing, the Supreme Court remanded the cause to the court of appeals to render an opinion, upon its review of the supplemented record, the issue of whether Defendant knowingly, intelligently, and voluntarily waived his right to counsel. View "State v. Jones" on Justia Law

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After the Supreme Court ruled in Ramos v. Louisiana, 140 S. Ct. 1390, 1394, 1397 (2020), that the Sixth Amendment, as incorporated against the states in the Fourteenth Amendment, requires a unanimous verdict to convict a defendant of a serious offense, movant moved for the Fifth Circuit's authorization to file a second or successive federal habeas petition.The court denied the motion for authorization to file a successive habeas corpus petition and held that, even if the court assumed that movant's current claim is different from the one he raised twelve years ago, it remains barred by 28 U.S.C. 2244(b)(2). The court explained that, even if it further assumed that Ramos constitutes a "new rule of constitutional law," the Supreme Court plainly has not made it retroactive to cases on collateral review. View "In Re: Larry Sharp" on Justia Law

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According to the complaint, “Plaintiff/Petitioner the People for the Ethical Operation of Prosecutors and Law Enforcement . . . is an association of residents of Orange County that includes at least one member who pays property taxes to Orange County.” People for the Ethical Operation of Prosecutors and Law Enforcement was a watchdog group seeking to ensure Orange County law enforcement agencies complied with their constitutional and statutory duties. The other plaintiffs were three individuals who were Orange County residents, and who had various interests in ensuring the integrity of the criminal justice system. The defendants were Todd Spitzer and Don Barnes who were the elected District Attorney and Sheriff, respectively. The gist of the complaint was that defendants operated an illegal and clandestine confidential informant (CI) program. The basic structure of the alleged CI program was that the Sheriff recruited confidential informants from among the prison population, moved those informants near a criminal defendant to facilitate a surreptitious interrogation, notwithstanding that the defendant was represented by counsel, which rendered the interrogations illegal under Massiah v. United States, 377 U.S. 201 (1964). The Sheriff allegedly kept extensive logs of these interactions, but kept those logs secret, even from the courts. The District Attorney used information from these interrogations, despite knowing their illegality, and did not disclose information about the CI program to defendants, in violation of their discovery duties. This appeal stemmed from a dismissal following a sustained demurrer in plaintiffs’ taxpayer suit against the Orange County officials. The trial court ruled that plaintiffs did not have standing to pursue taxpayer claims for waste under Code of Civil Procedure section 526a, nor a petition for a writ of mandate under Code of Civil Procedure section 1085. The Court of Appeal reversed, finding that the point of taxpayer standing, as well as the related doctrine of public interest standing in mandamus proceedings, was to confer standing on the public at large to hold the government accountable to fulfill its obligations to the public. "The fundamental rights at stake fit comfortably within the doctrines of taxpayer and public interest standing." View "People for the Ethical Operation of Prosecutors etc. v. Spitzer" on Justia Law