Justia Civil Rights Opinion Summaries

The Eleventh Circuit affirmed the district court's order dismissing plaintiffs' Title VII retaliation claims against Bradley Arant and grant of summary judgment to Marion Bank on the Title VII retaliation claims. Bradley Arant is an Alabama law firm that represented the Bank in litigation related to this case. Plaintiffs are related to Ragan Youngblood, a former Bank employee who was hired in February 2008 and fired seven months later, in September 2008. Ragan was the personal assistant to the Bank's president and CEO, Conrad Taylor. After Ragan was fired, she filed an EEOC charge alleging that Taylor had sexually harassed her and retaliated against her for complaining about that harassment. Plaintiffs claim that the Bank and the law firm took adverse action against them in retaliation for Ragan's protected conduct.Pursuant to Thompson v. N. Am. Stainless, LP, 562 U.S. 170, 174–75 (2011), the court concluded that plaintiffs must meet two prerequisites to even get out of the starting gate on a third-party Title VII retaliation claim against the Bank. In regard to plaintiffs' retaliation claim based on litigation filed by the firm on the Bank's behalf, and assuming the viability of plaintiffs' claim, the court assumed without deciding that the district court correctly concluded that plaintiffs qualified under Thompson as proper third-party retaliation claimants. The court concluded that summary judgment is warranted for the Bank based on the McDonnell Douglas standard. In this case, plaintiffs have failed to produce evidence sufficient to support a reasonable inference that but for Ragan's claim of sexual harassment, the Bank would not have engaged in the litigation that plaintiffs characterize as excessive.In regard to plaintiffs' claims based on the Bank's decision to stop referring legal work to Plaintiff Greg, the court assumed without deciding that his third-party claim can proceed. Analyzing the claim under the McDonnell Douglas framework, the court concluded that the Bank articulated a neutral, nonretaliatory reason for no longer referring legal work to Greg based on a conflict of interest. Furthermore, Greg has failed to produce any evidence of pretext. Finally, in regard to plaintiffs' claims against the law firm, the court concluded that the district court correctly dismissed these claims under Federal Rule of Civil Procedure 12(b)(6) where plaintiffs failed to allege an employment relationship between themselves and the firm. View "Tolar v. Bradley Arant Boult Cummings, LLP" on Justia Law

The Ninth Circuit affirmed the district court's denial of petitioner's federal petition for a writ of habeas corpus, which is governed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). Petitioner had pleaded guilty to first-degree murder and was sentenced to death. The district court granted a certificate of appealability as to five claims, and the panel later issued a certificate of appealability as to a sixth.The panel concluded that petitioner is not entitled to relief on any of the certified claims. In this case, petitioner is not entitled to relief on Claim 1, which was predicated on the alleged denial of his Sixth Amendment right to trial by jury, where fairminded jurists applying the governing beyond-a-reasonable-doubt standard could conclude that the absence of a jury trial did not affect either the finding of the (F)(6) aggravating factor or the determination that the mitigating evidence was not sufficiently substantial to call for leniency. The panel also rejected Claim 2, which alleged that trial counsel rendered ineffective assistance of counsel in presenting mitigation defense during the penalty phase; Claim 8, which alleged that petitioner's waiver of the privilege against self-incrimination was not knowing and voluntary; Claim 4, which alleged ineffective assistance of counsel with the same factual predicate as Claim 8; Claim 7, which alleged that Arizona courts violated the Eighth Amendment by applying an impermissible "causal nexus" test when assessing non-statutory mitigating circumstances; and Claim 12, which alleges that the sentencing court violated petitioner's Eighth Amendment rights. View "Sansing v. Ryan" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating Defendant's conviction and sentences and remanding for a new trial, holding that the trial court did not adequately confirm that Defendant waived his right to conflict-free counsel.Defendant and his co-defendant were charged with conspiracy, possession and transportation of marijuana for sale, and unlawful possession of drug paraphernalia. At Defendant's arraignment, the prosecutor noted his concern about one attorney representing both codefendants were they were competing defenses. Defense counsel dismissed the concerns because the codefendants had signed a waiver of potential conflict after being advised of their rights. The jury ultimately convicted both defendants on all counts. The Supreme Court vacated the convictions, holding that the joint representation presented an actual conflict that violated Defendant's Sixth Amendment right to conflict-free representation. The Supreme Court affirmed, holding that Defendant did not knowingly and intelligently waive the right to conflict-free counsel. View "State v. Duffy" on Justia Law

During an argument with his wife, Caniglia placed a handgun on a table and asked his wife to “shoot [him] and get it over with.” His wife left and spent the night at a hotel. The next morning, unable to reach her husband by phone, she called the police to request a welfare check. Officers encountered Caniglia on the porch of his home and called an ambulance, believing that Caniglia posed a risk to himself or others. Caniglia agreed to go to the hospital for a psychiatric evaluation if the officers would not confiscate his firearms. After Caniglia left, the officers located and seized his weapons. Caniglia sued, claiming that the officers had violated his Fourth Amendment rights. The First Circuit affirmed summary judgment in favor of the officers, extrapolating from the Supreme Court’s “Cady” decision a theory that the officers’ removal of Caniglia and his firearms from his home was justified by a “community caretaking exception” to the warrant requirement.A unanimous Supreme Court vacated. Cady held that a warrantless search of an impounded vehicle for an unsecured firearm did not violate the Fourth Amendment in light of the officers’ “community caretaking functions.” Searches of vehicles and homes are constitutionally different; the core of the Fourth Amendment’s guarantee is the right of a person to retreat into his home and “free from unreasonable governmental intrusion.” View "Caniglia v. Strom" on Justia Law

In 2007, a Louisiana jury found Edwards guilty of armed robbery, rape, and kidnapping. Louisiana law then permitted non-unanimous jury verdicts if at least 10 of the 12 jurors found the defendant guilty; 11 of 12 Edwards jurors returned a guilty verdict as to some crimes, and 10 of 12 jurors returned a guilty verdict as to others. After Edwards’s conviction became final, Edwards filed a federal habeas corpus petition. The district court rejected his argument that the non-unanimous jury verdict violated his constitutional rights as foreclosed by “Apodaca.” The Fifth Circuit denied a certificate of appealability.While Edwards’s petition for a writ of certiorari was pending, the Supreme Court repudiated Apodoca and held (“Ramos”) that a state jury must be unanimous to convict a criminal defendant of a serious offense.The Supreme Court affirmed with respect to Edwards. The Ramos jury-unanimity rule does not apply retroactively on federal collateral review. New rules of criminal procedure apply to cases on direct review, even if the defendant’s trial has already concluded but, historically, did not apply retroactively on federal collateral review unless a new rule constituted a “watershed” rule of criminal procedure. The Supreme Court has never found that any new procedural rule actually satisfies the “watershed” exception and acknowledged that the exception is “moribund.” Continuing to articulate a theoretical exception that never actually applies "offers false hope to defendants, distorts the law, misleads judges, and wastes" resources. View "Edwards v. Vannoy" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Atrium in an action brought by plaintiff, a former employee, alleging race discrimination, failure to promote, and hostile work environment in violation of the Iowa Civil Rights Act (ICRA). Absent further instruction from the Iowa Supreme Court to the contrary, the court will continue to apply the McDonnell Douglas framework to ICRA discrimination claims at summary judgment.Under the McDonnell Douglas framework, the court concluded that plaintiff failed to present evidence of any situation in which a white Atrium employee took a hotel room out of service, made a key to it, and then allowed unregistered guests to gain possession of the key, without being fired as a result. Furthermore, there is no evidence of white Atrium employees engaging in comparably serious misconduct without experiencing similarly harsh employment consequences. Therefore, the court concluded that plaintiff has not shown that similarly situated employees outside of his protected class were treated more favorably than him after engaging in similar misconduct. The court also concluded that summary judgment on the failure to promote claim was warranted where plaintiff failed to present evidence showing that Atrium's stated reason for declining to promote him was pretextual. Finally, plaintiff's hostile work environment claim failed because he failed to show that he experienced the workplace as abusive or that he felt that the harassment was so severe that it in effect altered the terms of his employment. View "Carter v. Atrium Hospitality" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no reversible error either in any issue raised by Defendant or in this Court's review under Mass. Gen. Laws ch. 33E.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress handwritten note and oral statements he made to officers while he was hospitalized; (2) Defendant was not entitled to reversal of his convictions on the grounds of error in the trial judge's evidentiary rulings; (3) the trial judge did not err in denying Defendant's motion for a new trial; and (4) there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Welch" on Justia Law

The Fifth Circuit withdrew its prior opinion and substituted the following opinion.Plaintiff filed suit against T-Mobile and Broadspire, alleging transgender discrimination under Title VII of the Civil Rights Act of 1964. Plaintiff's claims stemmed from his treatment while working as a retail employee at a T-Mobile store. The court concluded that, at the Rule 12(b)(6) stage, its analysis of the Title VII claim is governed by Swierkiewicz v. Sorema N.A., 534 U.S. 506 (2002)—and not the evidentiary standard set forth in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). Under Swierkiewicz, there are two ultimate elements a plaintiff must plead to support a disparate treatment claim under Title VII: (1) an adverse employment action, (2) taken against a plaintiff because of her protected status. The court explained that when a complaint purports to allege a case of circumstantial evidence of discrimination, it may be helpful to refer to McDonnell Douglas to understand whether a plaintiff has sufficiently pleaded an adverse employment action taken "because of" his protected status as required under Swierkiewicz.Applying these principles here, the court concluded that there is no dispute that plaintiff suffered an adverse employment action. However, the court concluded that plaintiff has failed to plead any facts indicating less favorable treatment than others "similarly situated" outside of the asserted protected class. In this case, the Second Amended Complaint does not contain any facts about any comparators at all, and there is no allegation that any non-transgender employee with a similar job and supervisor and who engaged in the same conduct as plaintiff received more favorable treatment. Therefore, the complaint does not plead any facts that would permit a reasonable inference that T-Mobile terminated plaintiff because of gender identity. Furthermore, plaintiff's Americans with Disabilities Act discrimination claim fails for similar reasons, and plaintiff's retaliation claim under Title VII is untimely.The court rejected plaintiff's contention that Bostock v. Clayton County, 140 S. Ct. 1731 (2020), changed the law and created a lower standard for those alleging discrimination based on gender identity. Rather, the court concluded that Bostock did not constitute an intervening change of law that warrants reconsideration under Rule 59(e). The court explained that Bostock defined sex discrimination to encompass sexual orientation and gender identity discrimination, but did not alter the meaning of discrimination itself. Therefore, where an employer discharged a sales employee who happens to be transgender—but who took six months of leave, and then sought further leave for the indefinite future, that is an ordinary business practice rather than discrimination. Finally, the district court did not abuse its discretion in denying further leave to amend. View "Olivarez v. T-Mobile USA, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained at the end of a traffic stop, holding that the traffic stop was unlawfully extended after its initial purpose had been resolved.Defendant entered a conditional plea to methamphetamine possession and child endangerment. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained at the end of the traffic stop because the stop was unlawfully extended before a drug dog alerted. The Supreme Court agreed, holding (1) Defendant did not waive his argument that the stop was unlawfully extended; and (2) Defendant's Fourth Amendment rights were violated because the law enforcement officer unlawfully extended the duration of the traffic stop after he completed the citation. View "Mahaffy v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted second-degree murder, holding that the overwhelming evidence of guilt precluded a conclusion that any alleged errors were prejudicial.On appeal, Defendant argued that his counsel provided ineffective assistance and that the prosecutor committed prejudicial misconduct. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's motion for a new trial due to ineffective assistance of counsel and that prosecutorial misconduct did not deny Defendant a fair trial. Specifically, the Court held that Defendant failed to demonstrate prejudice, which was dispositive of both of his claims. View "Leners v. State" on Justia Law