Justia Civil Rights Opinion Summaries

The Fifth Circuit held that the Chisom decree, which created Louisiana's one majority-black supreme court district, does not govern the other six districts. Therefore, the district court properly denied Louisiana's motion to dismiss this Voting Rights Act suit for lack of jurisdiction. In this case, the state argued that the Chisom decree centralizes perpetual federal control over all supreme court districts in the Eastern District of Louisiana, which issued the decree. The court concluded that the district court rejected that reading for good reason because it is plainly wrong. Rather, the present suit addresses a different electoral district untouched by the decree. View "Allen v. Louisiana" on Justia Law

Convicted of murder, Phillips has been incarcerated in Kentucky prisons since 1999. In 2014, Phillips and his cellmate got into a fight. Phillips later thought he had sprained his ankle. The pain and discoloration went away in a few weeks. Weeks later, Phillips noticed a growing lump on his calf. Dr. Tangilag measured the “mass” and ordered an ultrasound then scheduled a CT scan to rule out cancer. Phillips underwent the scan at a local hospital. Doctors concluded that a “plantaris rupture” was “related to an old injury/trauma” and assured Phillips that it was “not cancer or any bone lesion.” Phillips saw an outside orthopedic surgeon who agreed and concluded that Phillips did not need surgery. Dr. Tangilag met with Phillips a final time in August 2015. Phillips noted that he still experienced pain when walking. According to Phillips, the lump did not go away, and he continued to suffer pain.In 2016, Phillips sued, alleging that his doctors violated the Eighth Amendment’s ban on “cruel and unusual punishments” by refusing to surgically remove the lump. Medical staff ordered another ultrasound, which found nothing remarkable. Phillips was given pain medication and referred to physical therapy. The district court granted summary judgment to all defendants. The Sixth Circuit affirmed. Surgery is not the standard of care for a rupture, and a hematoma typically goes away on its own. Phillips lacks expert evidence suggesting that his doctors were grossly incompetent. View "Phillips v. Tangilag" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree criminal sexual conduct, holding that the modified plain error doctrine was not satisfied in this case.On appeal, Defendant argued that a statement made by the prosecutor during his jury trial required reversal of his conviction and a new trial. At issue was the prosecutor's statement to the jury during closing argument that a unanimous verdict on one element of the offense - specifically, whether Defendant acted with force or with coercion to accomplish the act of sexual penetration - was not required. The court of appeals affirmed, holding (1) the phrase "force or coercion in Minn. Stat. 609.342(a)(e)(i) sets forth alternative means for completing the sexual penetration element of the offense; and (2) therefore, a unanimous jury verdict on whether Defendant used force or coercion was not necessary. The Supreme Court affirmed, holding that no relief was warranted in this case. View "State v. Epps" on Justia Law

Plaintiff filed suit against prison officials, alleging that the delay in treatment of the cut on his hand amounted to deliberate indifference to a serious medical need. Captain Lewis asserted a qualified immunity defense, which the district court denied.The Eleventh Circuit reversed the district court's denial of qualified immunity to Lewis, concluding that Aldridge v. Montgomery, 753 F.2d 970 (11th Cir. 1985) (per curiam), did not place an objectively reasonable officer in Lewis's position on notice that his conduct was unconstitutional. In this case, although plaintiff's cut was bleeding while he was in Lewis's custody, nothing in the record supports the inference that, during Lewis's brief interaction with plaintiff, plaintiff's cut bled so continuously or profusely that it rose to the level of the circumstances in Aldridge. View "Wade v. Lewis" on Justia Law

In an action arising from a constitutional challenge to Missouri's remedial parole review process for individuals sentenced to mandatory life without the possibility of parole for homicide offenses committed as juveniles, a class of Missouri inmates who were sentenced to mandatory life without parole for such juvenile homicide offenses filed suit claiming that Missouri's parole review policies and practices violate their rights to be free from cruel and unusual punishment and their rights to due process of law under the U.S. Constitution and the Missouri Constitution. The district court granted summary judgment in favor of plaintiffs.The Eighth Circuit agreed with the district court that Missouri's policies and practices, when implemented and considered in combination, worked to deprive plaintiffs of their Eighth Amendment right to a meaningful opportunity to obtain release based upon demonstrated maturity and rehabilitation. The court explained that, because the parole review process in place under Senate Bill 590 failed to adequately ensure that juveniles whose crimes reflect only transient immaturity—and who have since matured—will not be forced to serve a disproportionate sentence, it violated the Eighth Amendment.The court affirmed the order of the district court determining that the parole review process of SB 590 violated plaintiffs' Eighth Amendment rights, and affirmed the order determining that Missouri cannot use a risk assessment tool in its revised parole proceedings unless it has been developed to address the unique circumstances of the JLWOP Class. The court vacated the order regarding appointment of counsel and remanded for further proceedings. Finally, the court denied plaintiffs' motion to strike. View "Brown v. Precythe" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to dismiss with prejudice or for absolute discharge based on late disclosures of discovery information resulting in delays Defendant argued implicated his speedy trial rights and denying Defendant's motion to suppress, holding that there was no error.On appeal, Defendant argued that the district court erred when it denied his motion to suppress the fruits of the search of his residence, two cell phones taken from his person incident to his unlawful arrest, information obtained from a search of the contents of his two cell phones, cell records and cell site location information from the cell phone service providers. Defendant also challenged the denial of his motion to dismiss and motion for complete discharge. The Supreme Court affirmed, holding that there was no merit to Defendant's assignments of error. View "State v. Short" on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated criminal sodomy and the requirement that he register as a sex offender for life under the Kansas Offender Registration Act (KORA), Kan. Stat. Ann. 22-4906(c), holding that there was no error in the proceedings below.On appeal, Defendant argued that retroactive application of KORA violates the federal constitutional prohibition against ex post facto punishment, constituted cruel and unusual punishment, and infringed on his right to due process. The appellate court affirmed. The Supreme Court affirmed, holding (1) Defendant's due process and cruel and unusual punishment arguments were waived and abandoned; and (2) KORA registration requirements are not punitive in purpose or effect, and therefore, retroactive application of KORA provisions to Defendant did not violate the Ex Post Facto Clause of the United States Constitution. View "State v. Davidson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals finding that lifetime registration requirements under the Kansas Offender Registration Act (KORA), Kan. Stat. Ann. 22-4906(c), were not punishment as applied N.R. and therefore did not trigger any constitutional provisions identified by N.R., holding that there was no error.N.R. pled guilty to rape and was adjudicated a juvenile offender. The gestate judge ordered N.R. to register as a sex offender for five years under KORA. Just before N.R.'s registration period was about to expire, the legislature amended KORA. As a result, N.R. was required to register for life. Later, the State charged N.R. for failing to register. N.R. filed a motion to dismiss, arguing that KORA's mandatory lifetime registration requirements for juvenile sex offenders violates the federal and state constitutional provisions against cruel and unusual punishment and the federal constitutional provision against ex post facto punishment. The district court found Defendant guilty. The Supreme Court affirmed, holding that KORA's mandatory lifetime registration requirements as applied to N.R. are not punishment and therefore do not violate the federal Ex Post Facto Clause or the prohibition against cruel and unusual punishment under the Kansas and United States Constitutions. View "State v. N.R." on Justia Law

Defendant-Appellee Southwest Airlines graded its new hires based on two overarching categories of criteria: Attitude and Aptitude. By all accounts, Plaintiff-appellant Krista Edmonds-Radford had the necessary Attitude for her position as a Southwest Customer Service Agent. Unfortunately, she failed to exhibit the necessary Aptitude, and Southwest terminated her for failing to meet expectations. That termination led to this disability-based lawsuit, in which Edmonds-Radford sued Southwest for disparate treatment, failure to accommodate, and retaliation under the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The district court granted summary judgment in favor of Southwest on all claims, and Edmonds-Radford appealed. After review, the Tenth Circuit determined: (1) Edmonds-Radford failed to establish her prima facie case or that Southwest’s proffered reason for her termination was pretextual; (2) Edmonds-Radford failed to present evidence she requested any accommodations in connection with her disability (in any event, Southwest provided all requested accommodations); and (3) because there was no proof she made any disability-based accommodation requests, Edmonds-Radford's retaliation claim based on such requests was doomed. "But even if Edmonds-Radford had made disability-based accommodation requests, her retaliation claim would still fail in light of our conclusions that Edmonds-Radford failed to establish that her disability was a determining factor in her termination, or that Southwest’s legitimate, nondiscriminatory reason for the termination was pretextual. Accordingly, the Court affirmed the district court's grant of summary judgment in favor of Southwest on all claims. View "Edmonds-Radford v. Southwest Airlines" on Justia Law

In 2006, a California death row inmate sued, arguing that California’s execution protocol violated the Eighth Amendment. The district court stayed the execution. After the state promulgated a new execution protocol, the District Attorneys of three counties unsuccessfully sought to intervene. While the District Attorneys’ appeal was pending, Governor Newsom withdrew California’s execution protocol and placed a moratorium on executions. The plaintiffs voluntarily dismissed their suit subject to conditions.The Ninth Circuit first held that this appeal was not mooted by Governor Newsom’s Order or by the stipulated dismissal. Nothing prevented Governor Newsom, or a future Governor, from withdrawing the Order and proceeding with preparations for executions. The suit could be revived upon the occurrence of any of three events specified in the Stipulation.The district court properly denied intervention as of right under Fed. R. Civ. P. 24(a) because the District Attorneys had not shown a significant protectable interest in the litigation. California law does not authorize them to defend constitutional challenges to execution protocols. The litigation concerned only the method by which the state may perform executions. The District Attorneys have neither the authority to choose a method of execution nor to represent the state entity that makes that choice. The district court properly denied permissive intervention under Fed. R. Civ. P. 24(b): there was no common question of law or fact between the District Attorneys’ claim or defense and the main action; intervention would delay the already long-drawn-out litigation. View "Cooper v. Newsom" on Justia Law