Justia Civil Rights Opinion Summaries

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In 1998, Haden pleaded no contest to infliction of corporal injury on a spouse and admitted a special allegation of personal use of a deadly weapon The trial court found true special allegations under the Three Strikes Law and sentenced him to 25 years to life. Haden had two robbery convictions in North Dakota The court of appeal affirmed, finding that the convictions could constitute strikes although the elements of robbery under North Dakota law differed from those under California law. Haden unsuccessfully sought habeas relief several times. In 2015, Haden filed another habeas petition, arguing that under the U.S. Supreme Court’s 2017 “Descamps” decision, the court made improper factual findings when treating the North Dakota convictions as strikes. In 2016, the California Supreme Court denied his petition “without prejudice to any relief … after this court decides” Gallardo. The 2017 Gallardo decision rejected the court's own 2006 “McGee” decision and held that a trial court considering whether to impose a sentence enhancement based on a defendant’s prior conviction may not make factual findings concerning the defendant’s conduct to impose the enhancement. In 2018, Haden filed another habeas petition, arguing the imposition of the North Dakota robberies as strikes contravened Gallardo because the court examined the record to determine the factual nature of those convictions. The court of appeal denied relief. Gallardo does not apply retroactively to Haden’s conviction. View "In re Haden," on Justia Law

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Plaintiff filed a 42 U.S.C. 1983 action against three police officers after plaintiff was shot and seriously injured while he was assisting the police apprehend a fugitive. Plaintiff alleged a section 1983 claim for involuntary servitude under the Thirteenth Amendment to the U.S. Constitution and a violation of substantive due process under the Fourteenth Amendment, as well as claims for negligence, wantonness, failure to train/supervise, and false imprisonment under Alabama state law. In this case, the officers told plaintiff that they would "throw some charges on [him]" if he did not agree to participate in a ruse to capture the fugitive. Plaintiff claimed that the threat of physical violence is what ultimately overcame his will and forced him to participate in the ruse. The Eleventh Circuit affirmed the district court's grant of summary judgment in favor of the officers based on qualified immunity, holding that the officers did not violate the Thirteenth or Fourteenth Amendment. Even assuming that there was a constitutional violation, the court held that it was not clearly established at the time that all objectively reasonable officers in their position would have known that what they said to plaintiff violated the Constitution's prohibition against involuntary servitude or its "nebulous" doctrine of substantive due process. Likewise, the court held that the officers are entitled to discretionary-function immunity on the state law claims. View "King v. Pridmore" on Justia Law

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Following an incident at President Trump's 2019 Social Media Summit involving Appellee Brian Karem, a journalist with a hard pass, and Sebastian Gorka, a Summit attendee, the Press Secretary suspended Karem's pass for thirty days on the ground that his conduct violated "professional journalistic norms." The DC Circuit affirmed the district court's grant of a preliminary injunction enjoining the enforcement of the suspension of Karem's hard pass credentials based on Fifth Amendment due process grounds. The court held that Karem is likely to succeed on his due process claim because, on this record, he lacked fair notice that the White House might punish his purportedly unprofessional conduct by suspending his hard pass for a month. The court also held that the remaining preliminary injunction factors counsel in favor of affirmance where Karem stands to suffer immediate irreparable harm absent an injunction, and the balance of the equities and the public interest factors also favor an injunction. The court limited the scope of the injunction to run only to the Press Secretary, rather than the Press Secretary and the President. View "Karem v. Trump" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals affirming the judgment of the circuit court convicting Defendant of assault in the second degree, holding that Defendant's constitutional right to cross-examine witnesses was violated when the circuit court prevented defense counsel from cross-examining the complainant about a potential source of bias. On appeal, Defendant argued that the circuit court erred in precluding the defense from cross-examining the complainant about disciplinary action the complainant might have faced as a United States Marine for instigating a fight in violation of its code of conduct provisions. Defendant further argued that the court erred in allowing a police officer to testify as to the contents of a security video that recorded the altercation but that had subsequently been destroyed. The ICA affirmed. The Supreme Court reversed, holding that because the defense was prevented from questioning the complainant about a potential source bias, the jury did not have sufficient information from which to make an informed appraisal of the complainant's motives or bias. The Court also provided guidance concerning the admissibility of other evidence as to the contents of a destroyed video recording under Haw. R. Evid. R. 1004 and 403. View "State v. Miranda" on Justia Law

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The Supreme Court reversed one of Defendant's convictions for robbery but affirmed the judgment of conviction in all other respects after adopting factors to guide the Court in deciding whether to consider an error's harmlessness despite the State's failure to argue it, holding that the district court's error in denying Defendant's motion to suppress was harmless. Defendant was found guilty of two counts of robbery with the use of a deadly weapon, murder with the use of a deadly weapon, and other crimes. The jury sentenced Defendant to death. On appeal, Defendant argued that the district court erred in denying his motion to suppress statements he made during an interview with detectives before his arrest. The Supreme Court concluded that the district court did err by denying Defendant's motion to suppress. The Court then adopted three factors to help determine whether the Court should consider an error's harmlessness when the State has not argued harmlessness in a death penalty case. After weighing those factors, the Court held (1) sua sponte harmless error review was appropriate in this matter, and the complained-of error was harmless; (2) one of the convictions for robbery was not supported by sufficient evidence; and (3) no other issue warranted relief. View "Belcher v. State" on Justia Law

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During the Coronavirus pandemic, Texas Governor Abbott postponed the May 2020 primary runoff elections to July 14; doubled the period for early voting by personal appearance; and declared that election officials would issue further guidance on social distancing and other precautions. The Democratic Party sought injunctive and declaratory relief that those eligible to vote by mail include all “eligible voter[s], regardless of age and physical condition . . . if they believe they should practice social distancing in order to hinder the known or unknown spread of a virus or disease.” The state trial court granted a preliminary injunction; an interlocutory appeal stayed the injunction. Texas Attorney General Paxton issued a statement, indicating that fear of contracting the Virus unaccompanied by a qualifying sickness or physical condition does not constitute a disability under the Texas Election Code for purposes of receiving a ballot by mail. The plaintiffs filed federal claims that Texas’s rules for voting by mail discriminate by age, restrict political speech, are unconstitutionally vague, and that Paxton’s open letter was a threat constituting voter intimidation. The Fifth Circuit denied relief, referring to the district court’s “audacity” in entering a sweeping preliminary injunction, weeks before the election, that requires officials to distribute mail-in ballots to any eligible voter who wants one. The Constitution principally entrusts the safety and the health of the people to politically accountable state officials The spread of the Virus has not given unelected federal judges a roving commission to rewrite state election code. View "Texas Democratic Party v. Abbott" on Justia Law

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In this action brought under 42 U.S.C. 1983, the Eighth Circuit affirmed the district court's grant of summary judgment in favor of the Police Defendants, a probation officer, various Board Defendants, and the City. Plaintiff filed suit after his convictions related to armed robbery were reversed, and the victim of the crime did not want to testify at another trial, the State declined to retry the case, and plaintiff was released. The court held that the district court correctly granted summary judgment to the Police Defendants on the section 1983 Brady claim, because plaintiff failed to establish a genuine dispute of material fact about whether the Police Defendants violated his constitutionally protected federal rights by suppress or destroying evidence in bad faith. The court also held that, because the record evidence does not create a genuine dispute of material fact regarding plaintiff's fabrication-of-evidence claims, the district court did not err in granting summary judgment to the Police Defendants. Furthermore, the district court court did not err in granting summary judgment to the Police Defendants on plaintiff's failure-to-investigate claim. Finally, the court held that plaintiff's conspiracy and Monell claims necessarily failed. View "McKay v. City of St. Louis" on Justia Law

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The Supreme Court affirmed the order of the postconviction court denying Appellant's claim of ineffective assistance of counsel for failure to challenge a biased juror, holding that the postconviction court's finding that defense counsel had a reasonable, strategic basis for not challenging the juror was supported by competent, substantial evidence. Appellant was convicted of first-degree murder, kidnapping, and robbery. Appellant was sentenced to death for the murder. Appellant later filed a motion for postconviction relief, alleging, among other things, ineffective assistance of counsel for failure to challenge a biased juror. After the Supreme Court remanded the issue for an evidentiary hearing, the postconviction court denied the claims, finding that counsel had chosen not to challenge the juror as part of a reasonable trial strategy. The Supreme Court affirmed, holding that competent, substantial evidence supported the finding that counsel made a reasonable decision not to challenge the juror; and (2) this strategy was objectively reasonable from the perspective of believing that it would operate to Defendant's advantage in this particular trial. View "Patrick v. State" on Justia Law

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Coty, who is intellectually disabled, was convicted of predatory criminal sexual assault of a child and aggravated criminal sexual abuse for conduct committed against a six-year-old. Because Coty had a prior conviction for aggravated criminal sexual assault of a nine-year-old, the court had no discretion and sentenced him to the statutorily prescribed term of mandatory natural life in prison. Coty argued that the sentence violated the Eighth Amendment and the Illinois Constitution because it categorically forbade the sentencing judge from considering his intellectual disability and the circumstances of his offense. He also argued that the statutory scheme, as applied to him, violated the Illinois Constitution's proportionate penalties clause. The appellate court found the mandatory sentencing statute unconstitutional as applied. On remand, Coty, who was then 52 years old, was sentenced to 50 years in prison. The appellate court vacated, finding that the sentence amounted to an unconstitutional de facto life sentence, violating Illinois’s proportionate penalties clause. The Illinois Supreme Court reversed, reinstating the sentence. The original sentence of natural life imprisonment did not violate the proportionate penalties clause. The penalty challenged in Coty’s initial appeal was not, as applied to him, clearly in excess of the legislature’s constitutional authority to prescribe. Some of the diminished capacity factors that the Supreme Court in Atkins found reduced culpability make Coty a continuing danger to re-offend. The purpose of the mandatory, natural life sentence for repeat sex offenders is to protect children by rendering it impossible for the incorrigible offender to re-offend. View "People v. Coty" on Justia Law

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The Libertarian Party filed suit against the Secretary of State of Georgia, alleging that Georgia's ballot-access requirements for third-party and independent candidates violated their associational rights under the First and Fourteenth Amendments and their Equal Protection rights under the Fourteenth Amendment. The Eleventh Circuit vacated the district court's grant of summary judgment to the Secretary, holding that the district court's failure to apply the Supreme Court's test for the constitutionality of ballot-access requirements, as articulated in Anderson v. Celebreeze, 460 U.S. 780 (1983), constitutes reversible error. Accordingly, the court remanded to the district court with instructions to conduct in the first instance the Anderson test and to consider the Party's Equal Protection claim. View "Cowen v. Georgia Secretary of State" on Justia Law