Justia Civil Rights Opinion Summaries

The Supreme Court reversed the judgment of the court of appeal concluding that a defense counsel's failure to object at trial, before People v. Sanchez, 63 Cal.4th 665 (2016), was decided, forfeited a claim that a gang expert's testimony related case-specific hearsay in violation of the confrontation clause, holding that a defense counsel's failure to object under such circumstances does not forfeit a claim based on Sanchez. Sanchez held that an expert cannot relate case-specific hearsay to explain the basis for her opinion unless the facts are independently proven or fall within a hearsay exception. Defendants in the instant case were each convicted of two counts of first degree special circumstance murder and other crimes. Before Defendants' appeals were resolved, the Supreme Court issued its opinion in Sanchez. On appeal, one of the defendants argued that a gang expert testified to case-specific hearsay in violation of the confrontation clause. The court of appeal held that the defendant's failure to object to case-specific hearsay in expert testimony at trial forfeited any Sanchez claim on appeal. The Supreme Court reversed, holding that the court of appeal erred in finding that the defendant forfeited his claim on appeal based on Sanchez by failing to object at a trial that occurred before Sanchez was decided. View "People v. Perez" on Justia Law

The Ninth Circuit affirmed the district court's dismissal of an action brought after the death of Arizona Senator John McCain, challenging the constitutionality of an Arizona statute that governs appointments and elections in the aftermath of a vacancy in the United States Senate. Plaintiffs argued that the November 2020 vacancy election date and the 27-month interim appointment duration violate the time constraints implicit in the Seventeenth Amendment. The panel affirmed the district court's dismissal of this challenge based on failure to state a claim, because there was no authority for invalidating the state statute on this basis. Although the panel found plaintiffs' interpretation a possible one based on the text and history of the Seventeenth Amendment, the panel concluded that it was foreclosed by binding precedents. Plaintiffs also argued that the November 2020 vacancy election date impermissibly burdens their right to vote as protected by the First and Fourteenth Amendments. The panel affirmed the district court's dismissal of this challenge based on failure to state a claim, because important state regulatory interests justify what was a reasonable and nondiscriminatory restriction on plaintiffs' right to vote. Finally, plaintiffs challenge Arizona's statutory mandates that the Governor must make a temporary appointment and must choose a member of the same party as the Senator who vacated the office. The panel affirmed the district court's dismissal of this challenge based on failure to state a claim, and rejected plaintiffs' interpretation of the relevant Seventeenth Amendment language. The panel also affirmed the district court's dismissal of the challenge based on lack of standing where there was no harm on the basis of representation by a Republican and no redressability where the Republican Governor would appoint a Republican anyway. View "Tedards v. Ducey" on Justia Law

On remand from the Supreme Court, the Ninth Circuit affirmed the district court's order denying defendant's motion for summary judgment on plaintiff's claims under the Equal Pay Act (EPA). The en banc court held that plaintiff's prior rate of pay was not a "factor other than sex" that allows Fresno County's Office of Education to pay her less than male employees who perform the same work. The en banc court also held that only job-related factors may serve as affirmative defenses to EPA claims. The en banc court wrote that the express purpose of the Act was to eradicate the practice of paying women less simply because they are women, and that allowing employers to escape liability by relying on employees' prior pay would defeat the purpose of the Act and perpetuate the very discrimination the EPA aims to eliminate. Therefore, the en banc court held that an employee's prior pay cannot serve as an affirmative defense to a prima facie showing of an EPA violation. The en banc court overruled Kouba v. Allstate Ins. Co., 691 F.2d 873 (9th Cir. 1982), which held that prior pay could qualify as an affirmative defense if the employer considered prior pay in combination with other factors and used it reasonably to effectuate a business policy. View "Rizo v. Yovino" on Justia Law

J.H., a 14-year-old pretrial detainee, was placed in segregated housing in Williamson County’s juvenile detention facility after other juveniles alleged that he threatened to assault them. J.H. suffers from Pediatric Autoimmune Neuropsychiatric Disorder Associated with Streptococcal Infections (PANDAS), which often manifests in psychiatric symptoms. In a suit under 42 U.S.C. 1983, J.H. alleged that his placement in segregated housing for a month in 2013 amounted to unconstitutional punishment; that a detention monitor, Cruz, sexually assaulted him during this period, as a result of Williamson County’s failure to train Cruz; and that during that period, officials failed to provide adequate medical care. The Sixth Circuit affirmed summary judgment in favor of the defendants. The official is entitled to qualified immunity. While the punishment imposed on J.H. was excessive in relation to the verbal threats he made, the right at issue was not established with sufficient specificity as to hold it clearly established as of 2013. J.H. met with and received medication from multiple medical professionals, none of whom requested that the facility make any accommodations for J.H.’s medical needs. J.H. has not shown a “direct causal connection” between the failure to train Cruz and his alleged assault; it is far from clear that any lack of training was the “moving force” behind Cruz’s decision to sexually assault a child. View "J.H. v. Williamson County" on Justia Law

The Supreme Court affirmed the judgment of the post conviction court summarily denying Defendant's eighth successive motion to vacate his judgment of conviction and sentence, holding that all of Defendant's postconviction claims were legally insufficient or based on allegations that were conclusively refuted by the record. Defendant was convicted of first-degree murder and sentenced to death. The Supreme Court affirmed. This case concerned Defendant's eighth successive motion to vacate the judgment of conviction and sentence. Along with his eighth successive motion Defendant filed a motion to compel discovery documents from the Office of the State Attorney. The postconviction court summarily denied Defendant's eighth successive postconviction motion and denied his motion to compel. The Supreme Court affirmed, holding (1) Defendant was not entitled to an evidentiary hearing on a newly discovered evidence claim alleging spoliation of evidence and a Brady violation; (2) Defendant was not entitled to an evidentiary hearing on his ineffective assistance of counsel claims; (3) the trial court did not err in summarily denying a standalone actual innocence claim; and (4) because Defendant failed to demonstrate his entitlement to the requested records the postconviction court correctly denied his motion to compel. View "Sweet v. State" on Justia Law

The Supreme Court reversed Defendant's convictions for aggravated murder and other felonies and the death sentence imposed by the county court of common pleas, holding that Defendant was deprived of his constitutional right to the effective assistance of counsel when defense counsel, during voir dire, failed to question or strike a racially biased juror. On appeal, Defendant presented seventeen propositions of law. In his seventeenth proposition of law, Defendant argued that his trial counsel provided ineffective assistance by failing to question and strike a juror who made racially biased statements on her juror questionnaire and that counsel's deficient performance denied him a fair and impartial jury. The Supreme Court found this issue dispositive and reversed Defendant's convictions and sentence, holding that defense counsel's performance during voir dire was objectively unreasonable and that counsel's deficient performance prejudiced Defendant in violation of his constitutional right to effective assistance of counsel. The Court remanded the case to the trial court for a new trial. View "State v. Bates" on Justia Law

Plaintiffs filed suit against the school district and its superintendent, alleging free speech and retaliation claims in violation of their First Amendment rights under 42 U.S.C. 1983; Article 1, Section 8 of the Texas Constitution; and the Texas Whistleblower Act. Plaintiffs, the former principal and assistant principal of an elementary school, served on a 504 committee which convened for the purpose of implementing regulations under Section 504 of the Rehabilitation Act of 1973. Plaintiffs were terminated after an investigation determined that they intentionally authorized inappropriate student testing accommodations based on a misapplication of Section 504 eligibility requirements. The Fifth Circuit affirmed the district court's judgment, holding that the superintendent was entitled to qualified immunity because it was not clearly established at the time whether First Amendment liability can attach to a public official who did not make the final employment decision. The court also held that the district court did not err in granting summary judgment on plaintiff's First Amendment claims, because plaintiffs' calls to TEA regarding Section 504 construction and application at the elementary school were clearly activities undertaken in the course of performing their jobs and these actions were therefore not protected by the First Amendment. Finally, the court held that plaintiffs were not entitled to recover lost wages because they failed to exercise reasonable diligence to mitigate their damages; the district court did not err in denying plaintiffs' motion for rescission or modification; the district court did not err in instructing the jury that the IHE's findings were preclusive; and the district court did not err in relying on the jury's verdict that plaintiffs did not report a violation of law in good faith. View "Powers v. Northside Independent School District" on Justia Law

The Supreme Court answered in the negative questions of law certified from the United States District Court for the Middle District of Tennessee regarding the constitutionality of Tennessee's statutory cap on noneconomic damages, Tenn. Code Ann. 29-30-102, holding that the statutory cap does not violate the right to trial by jury, the doctrine of separation of powers, or the equal protection provisions of the Tennessee Constitution. Specifically, the Supreme Court answered (1) the noneconomic damages cap in civil cases imposed by section 29-39-102 does not violate a plaintiff’s right to a trial by jury, as guaranteed in Tenn. Const. art. I, 6; (2) the noneconomic damages cap in civil cases imposed by section 29-39-102 does violate Tennessee’s constitutional doctrine of separation of powers between the legislative branch and the judicial branch; and (3) the noneconomic damages cap in civil cases imposed by section 29-39-102 does not violate the Tennessee Constitution by discriminating disproportionately against women. View "McClay v. Airport Management Services, LLC" on Justia Law

Several Organizations and eligible voters filed suit challenging the constitutionality of Texas's winner-take-all (WTA) method of selecting presidential electors, claiming that the WTA violates the one-person, one-vote principle rooted in the Equal Protection Clause of the Fourteenth Amendment and freedom of association under the First and Fourteenth Amendments. The Fifth Circuit affirmed the district court's grant of defendants' motion to dismiss. The court held that Williams v. Va. State Bd. of Elections, 288 F. Supp. 622 (E.D. Va. 1968), aff'd, 393 U.S. 320 (1969) (per curiam), did not confront an argument that appointing presidential electors through a WTA system violates freedom of association, and thus the court must address the substance of those claims. The court also held that plaintiffs failed to state a cognizable burden, and rejected plaintiffs' claims that WTA burdens their right to a meaningful vote, to associate with others, or to associate with candidates and petition electoral representatives. More generally, the court held that plaintiffs failed to allege any harms suffered by reasons of their views. Rather, the court wrote that any disadvantage plaintiffs allege is solely a consequence of their lack of electoral success. View "League of United Latin American Citizens v. Abbott" on Justia Law

McDowell and Hutchison planned and executed a burglary and an attempted armed robbery of a drug dealer. Hutchison shot and killed the drug dealer. Although he was not the actual killer, McDowell was sentenced to life imprisonment without the possibility of parole after a jury convicted him of, among other things, first-degree murder (Pen. Code 187(a)) and found true robbery-murder and burglary-murder special circumstances (190.2(a)(17)(A), (G)). After the California Supreme Court’s Banks (2015) and Clark (2016) decision, McDowell sought habeas corpus relief, challenging the special circumstance findings. The court of appeal denied relief, holding that the “major participant” and “reckless indifference to human life” findings are adequately supported. McDowell’s decision to arm himself with a palm knife should be viewed in combination with the particularly risky crime that he planned and led—a home invasion robbery of a methamphetamine dealer. McDowell’s proximity to the crime and opportunity to restrain Hutchison also increased his culpability. View "In re McDowell" on Justia Law