Justia Civil Rights Opinion Summaries

Plaintiffs, black citizens of Misssissippi who have lost their right to vote in Mississippi because they were convicted of crimes enumerated in section 241 of the Mississippi Constitution, filed suit alleging that section 241 violates the Fourteenth Amendment because it was enacted with a discriminatory purpose.After determining that plaintiffs have Article III standing and that the suit is not barred by sovereign immunity, the Fifth Circuit agreed with the district court that per Cotton v. Fordice, 157 F.3d 388 (5th Cir. 1998), the discriminatory taint of the 1890 provision was removed by the amendment processes in 1950 and 1968. Furthermore, under the rule of orderliness, the court was bound by that decision. Accordingly, the court affirmed the district court's grant of summary judgment for the Secretary of State. View "Harness v. Hosemann" on Justia Law

Joiner is a 31‐year‐old prisoner serving an eight-year sentence at U.S. Penitentiary Marion for a drug crime. In July 2020, amid the COVID‐19 pandemic, Joiner sought compassionate release under 18 U.S.C. 3582(c)(1)(A), citing “extraordinary and compelling reasons,” self‐reported hypertension, a body mass index (BMI) of 28.9 (the “over‐weight” category), and his skin color. He argued that Black Americans have disproportionately suffered from COVID‐19 because “society has put them in worse positions.” He cited a CDC article to argue that Black people in the U.S. face a higher risk of hospitalization and death from COVID‐19, and other articles to contend that, even though skin color should not affect health outcomes from infectious diseases, “our society” delivers subpar health care to “people with black skin,” even when controlling for class, comorbidities, and access to health insurance. The government contended that Joiner’s medical records did not contain evidence of hypertension and that his BMI did not place him at “high risk” for severe COVID‐19 complications.The district court ruled that Joiner did not present extraordinary and compelling reasons for release, without comment on Joiner’s racial disparity argument. The Seventh Circuit affirmed. The cited articles identify multiple societal factors that are not relevant to Joiner’s individual situation in federal prison. Without any factual basis tying those broader societal concerns to Joiner’s individual situation, the district court was not required to address the argument. View "United States v. Joiner" on Justia Law

The Ninth Circuit affirmed the district court's grant of summary judgment for defendants in an action brought by plaintiff and his family under the Fair Housing Amendments Act (FHAA). Plaintiff and his family sought to extend their tenancy in defendants' property based on plaintiff's medical condition.The panel agreed with the district court that, under 42 U.S.C. 3604(f)(3)(B), making "accommodations in rules, policies, practices, or services" was not necessary to afford plaintiff and his family "equal opportunity to use and enjoy a dwelling." The panel held that, absent an accommodation, the plaintiff's disability must cause the plaintiffs to lose an equal opportunity to use and enjoy a dwelling. In this case, defendants offered plaintiff and his family, who were on a month-to-month tenancy, terminable at will, a new lease for one year at an increased rent. However, plaintiff and his family turned down the new lease, and never credibly argued that they turned down the lease for any reason related to plaintiff's disability. Upon termination of the lease, plaintiff and his family were in the same position as a family with no disability that had had its lease terminated. The panel explained that it could not find a connection between plaintiff's disability and his request to remain in the home until January 22, 2018. Therefore, defendants were under no obligation to extend the tenancy-termination date. Finally, the panel agreed with the Third and Sixth Circuits and held that there is no standalone liability under the FHAA for a landlord’s failure to engage in an interactive process. View "Howard v. HMK Holdings, LLC" on Justia Law

Kelly, an off-duty Chicago police officer, shot his friend LaPorta in the head during an argument after a night of drinking together. LaPorta’s injuries left him severely, permanently disabled. LaPorta sued the city under 42 U.S.C. 1983, which provides a federal remedy against state actors who deprive others of rights secured by the federal Constitution and laws, arguing that the city had inadequate policies in place to prevent the shooting. He identified several policy shortcomings: the failure to have an “early warning system” to identify officers who were likely to engage in misconduct, the failure to adequately investigate and discipline officers who engage in misconduct, and the perpetuation of a “code of silence” that deters reporting of officers who engage in misconduct.A jury awarded LaPorta $44.7 million in damages. The Seventh Circuit reversed. Whatever viability LaPorta’s claim might have under state tort law, it has no foundation in constitutional law. When Kelly shot LaPorta, he was not acting as a police officer but as a private citizen. LaPorta claimed that he was deprived of his due-process right to bodily integrity but it has long been settled that “a State’s failure to protect an individual against private violence … does not constitute a violation of the Due Process Clause.” View "First Midwest Bank v. City of Chicago" on Justia Law

The Supreme Court reversed the judgment of the court of criminal appeals dismissing Defendant's appeal and dismissed Defendant's convictions for possession with the intent to deliver more than twenty-six grams of methamphetamine and possession of drug paraphernalia, holding that the initial search of Defendant's house during which law enforcement discovered illegal contraband was unlawful.Defendant pled guilty but specifically reserved a certified question of law pertaining to the legality of the search in this case. The court of criminal appeals dismissed the appeal, determining that the certified question was not dispositive because the evidence would have been admissible notwithstanding the search in question under the inevitable discovery doctrine. The Supreme Court reversed and dismissed Defendant's convictions, holding (1) the inevitable discovery doctrine did not apply in this case; and (2) the State did not carry its burden of proving that either exigent circumstances or voluntary consent justified their warrantless search of Defendant's home. View "State v. Scott" on Justia Law

The First Circuit reversed the decision of the district court granting Defendant's motion to suppress the evidence discovered during an inventory search of a vehicle that a Massachusetts State Police trooper stopped on a highway, holding that the trooper had reasonable suspicion to make the stop.In his motion to suppress, Defendant argued that the warrantless search of his vehicle violated the Fourth Amendment. In response, the government argued that the inventory search fell within the community caretaking function. The district court disagreed, holding that there was no non-investigatory reason to conduct the inventory search. The First Circuit reversed, holding that the district court erred in granting Defendant's motion to suppress. View "United States v. Rivera" on Justia Law

The Supreme Court vacated the order of the circuit court modifying the disposition of this case to terminate Petitioners' parental rights under W. Va. Code Ann. 49-4-604(c)(6), holding that the circuit court erred in modifying the disposition absent a motion under section 49-4-606 and that the parties were deprived of due process when they were not notified that the circuit court intended to take up a motion to modify disposition.In 2017, the circuit court ordered a "section 5" disposition, concluding that Petitioners were unwilling or unable to provide for B.W.'s needs and that there were no parenting services available specifically tailed to Petitioners' need for reasonable accommodation under the Americans with Disabilities Act, 42 U.S.C. 12101 through 12213. The court did not terminate Petitioners' parental rights at that time but dismissed the case from its docket. In 2019, the circuit court held a status hearing and sua sponte modified the case's disposition to terminate Petitioners' parental rights. The Supreme Court vacated the order, holding that termination of Petitioners' parental rights violated the procedure required by section 49-4-606 to modify disposition and denied Petitioners due process. View "In re B.W." on Justia Law

After plaintiff was convicted in 1993 for misdemeanor assault and battery of a family member, he was prohibited for life under 18 U.S.C. 922(g)(9) from possessing a firearm unless he obtains a pardon or an expungement of his conviction. Plaintiff filed suit seeking a declaration that section 922(g)(9) is unconstitutional as applied to him.The Fourth Circuit affirmed the district court's grant of summary judgment to defendants, holding that section 922(g)(9) is constitutional as applied to plaintiff. The court applied a two-prong approach in considering as-applied Second Amendment challenges. First, the court assumed without deciding that domestic violence misdemeanants are entitled to some degree of Second Amendment protection. Second, the court applied intermediate scrutiny to consider plaintiff's challenge. Applying United States v. Staten, 666 F.3d 154 (4th Cir. 2011), which rejected an as-applied Second Amendment challenge to section 922(g)(9), the court concluded that the evidence showed "a reasonable fit" between the statute and the substantial governmental objective of reducing domestic gun violence. In reaching this conclusion, the court adopted the approach of its sister circuits and declined to read into the statute an exception for good behavior or for the passage of time. View "Harley v. Wilkinson" on Justia Law

In this civil rights action alleging violations of 42 U.S.C. 1981, 1983, and 1985, the First Circuit affirmed the judgment of the district court dismissing with prejudice Plaintiff's claims against Stanley Spiegel and later granting summary judgment in favor of the remaining defendants, holding that the allegations against Spiegel failed to state a claim upon which relief can be granted.Defendant's second amended complaint named as defendants the Town of Brookline, Massachusetts, the Brookline Board of Selectmen, certain members of the Board, Spiegel (a town meeting member), and others. Plaintiff alleged that Defendants discriminated against him on the basis of race, retaliated against him for exercising his First Amendment rights, and conspired to enforce the Town's policy of opposing racial equality. After the district court disposed of Defendant's claims he appealed, arguing that the district court erred by dismissing his claims against Spiegel. The First Circuit affirmed, holding that there were no facts pleaded in the complaint sufficient to ground a reasonable inference that Spiegel was liable to Defendant for any of the causes of action he brought. View "Alston v. Town of Brookline, Massachusetts" on Justia Law

The First Circuit affirmed the judgment of the district court revoking Defendant's supervised release and sentencing him to six months of imprisonment and an additional eight years of supervised release, holding that Defendant's constitutional rights were not violated.On appeal, Defendant argued that the revocation of his release violated his privilege against self-incrimination under the Fifth Amendment and that his suspension from treatment violated his Fifth Amendment due process right. The First Circuit disagreed, holding (1) a court in this circuit can impose mandatory periodic polygraph examinations in connection with sex offender treatment programs as a condition of supervised release, where the condition prohibits basing revocation in any way on the defendant's assertion of his Fifth Amendment privilege against self-incrimination; (2) in this case, no penalty was attached to Defendant's potential invocation of the Fifth Amendment privilege, and therefore, his privilege was not violated; and (3) Defendant's suspension from sex offender treatment did not violate his Fifth Amendment right to due process. View "United States v. Rogers" on Justia Law