Justia Civil Rights Opinion Summaries

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The Supreme Court affirmed the order of the circuit court dismissing Plaintiff's claims against a sheriff's deputy, a county, and its sheriff's department alleging that his earlier arrest violated his constitutional rights and was intentional infliction of emotional distress and battery, holding that Plaintiff's claims were time barred and that Plaintiff's motions for disqualification were properly denied. The circuit court dismissed Plaintiff's claims because he did not file within the two-year statute of limitations. On appeal, Plaintiff argued that the circuit judge should have been disqualified from the case and that the tolling provision of W. Va. Code 55-17-3(a) should have applied once he gave notice of his claim to the sheriff's department. The Supreme Court affirmed, holding (1) the tolling provision of section 55-17-3(a) did not apply because the sheriff's department is not part of the executive branch of state government; and (2) Plaintiff's allegations that the circuit judge should have been disqualified were properly adjudicated by the Chief Justice of the Supreme Court and were without merit. View "Patton v. County of Berkeley, West Virginia" on Justia Law

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Yusuf Awadir Abdi sued the directors of several federal agencies challenging his placement on a federal government’s terrorist watchlist. He alleged his being on the list subjected him to enhanced screening at the airport and requires the government to label him as a “known or suspected terrorist” and to disseminate that information to government and private entities. As a result of these alleged consequences, Abdi alleged placement on the Selectee List violated his Fifth Amendment rights to substantive and procedural due process and consequently the Administrative Procedure Act, for which he sought declarative and injunctive relief. The district court dismissed Abdi’s complaint with prejudice under Federal Rule of Civil Procedure 12(b)(6). Finding no reversible error in that decision, the Tenth Circuit affirmed dismissal. View "Abdi v. Wray" on Justia Law

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In the visiting room, a friend handed Pennsylvania inmate Thomas a bag of M&Ms. He ate one and then quickly drank soda. A guard, believing that Thomas had ingested contraband, removed him to a dry cell for observation until natural processes allowed the ingested contraband to be retrieved. The sink and toilet were capped. Dry cells lack all linens and moveable items other than a mattress. Inmates’ clothes are exchanged for a smock; their movements are carefully controlled to prevent them from concealing or disposing of contraband. To expedite his release from the dry cell, Thomas was offered and accepted laxatives. Over the next four days, Thomas had 12 bowel movements and was x-rayed. No evidence of contraband was found. He was confined to the dry cell for five more days. After exhausting his administrative remedies, Thomas filed suit under 42 U.S.C. 1983. The district court granted the defendants summary judgment. The Third Circuit reversed in part. Whether there was a penological justification to continue Thomas’s confinement in the dry cell after four days constitutes a disputed issue of material fact. When confinement in a dry cell is not foul or inhuman and serves a legitimate penological interest, it will not violate the Eighth Amendment. View "Thomas v. Tice" on Justia Law

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The Supreme Court affirmed the judgment of the juvenile court committing fifteen-year-old A.M. to the Department of Correction (DOC), holding that A.M. failed to demonstrate that he received ineffective assistance of counsel under the circumstances of this case. After a true finding of disorderly conduct, A.M. was placed on supervised probation. But due to A.M.'s conduct, the probation department recommended his placement with the DOC. After a disposition modification hearing, the juvenile court committed A.M. to the DOC for an indeterminate period. On appeal, A.M. argued that his attorney rendered ineffective assistance during the modification hearing. At issue in this case was whether the standard for deciding the claim was founded in the Sixth Amendment's right to counsel for a criminal proceeding or in the Fourteenth Amendment's due process clause. The Supreme Court held (1) a due process standard governs a child's claim that he received ineffective assistance in a disposition-modification hearing during his delinquency proceedings; and (2) A.M. received effective assistance of counsel during his modification hearing. View "A.M. v. State" on Justia Law

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Plaintiff filed a 42 U.S.C. 1983 action against four state defendants, alleging that they violated his Eighth and Fourteenth Amendment rights by holding him in state custody for four months after the expiration of his federal sentence, where the state sentencing court had originally directed that plaintiff's state and federal sentences should run concurrently. The district court denied the state defendants' motion for summary judgment. The Second Circuit held that, under Mathews v. Eldridge, 424 U.S. 319 (1976), the state defendants violated the Due Process Clause by implementing plaintiff's sentence in the manner they did without providing adequate notice to the state sentencing court and the attorneys present at plaintiff's state sentencing. The court held, nonetheless, that the state defendants were entitled to qualified immunity from all of plaintiff's constitutional claims. In regard to the Fourteenth Amendment claim, the court held that there was no clearly established law considering whether prison officials implementing a state sentence violate the Constitution by failing to provide notice to the sentencing court and attorneys. Likewise, in regard to the Eighth Amendment claim, there was not clearly established right the state defendants violated in this case. Accordingly, the court reversed and remanded with instructions to grant the motion for summary judgment. View "Francis v. Fiacco" on Justia Law

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Jonella Tesone claimed that Empire Marketing Strategies (“EMS”) discriminated against her under the Americans with Disabilities Act (“ADA”) when it terminated her employment. The district court granted summary judgment to EMS. EMS hired Tesone as a Product Retail Sales Merchandiser. Her job duties included changing or “resetting” retail displays in grocery stores. When she was hired, Tesone informed EMS that she had back problems and could not lift more than 15 pounds. On appeal, Tesone alleged the district court erred when it denIed her motions: (1) to amend the scheduling order to extend the time for her to designate an expert; and (2) amend her complaint. She also contended the district court erred in granting summary judgment to EMS. The Tenth Circuit determined the district court did not err with respect to denying Tesone’s motions, but did err in granting summary judgment in favor of EMS. “Whether Ms. Tesone can make a prima facile case of a disability, and whether her doctor’s note can be considered at summary judgment, is open to the district court’s further consideration.” View "Tesone v. Empire Marketing Strategies" on Justia Law

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The Supreme Court affirmed Defendant's convictions and sentences for four counts of first degree sexual assault, holding that Defendant was not entitled to relief on his claims of error. Specifically, the Supreme Court held (1) the district court did not commit plain error when it admitted the DNA evidence that linked Defendant to the assaults; (2) the district court did not abuse its discretion when it overruled Defendant's motion to remove counsel and appoint substitute counsel; and (3) regarding Defendant's claims of ineffective assistance of trial counsel, either the record on direct appeal showed the claim was without merit or that the record was not sufficient to review the claim. View "State v. Weathers" on Justia Law

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The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress all evidence stemming from a stop of his vehicle, holding that the district court erred in finding that the deputy developed reasonable suspicion of other criminal activity before unreasonably prolonging the stop. After Defendant was stopped for violating Iowa Code 321.297(2) the deputy asked Defendant and his passenger questions. Finding the answers suspicious, the deputy sought permission for a consent search. Defendant consented. After a search of the car, the deputy located more than eighty pounds of marijuana in the trunk. Defendant filed a motion to suppress the evidence, which the district court denied. The Supreme Court reversed, holding that the delay of Defendant's stop was measurable, unreasonable, and in violation of Defendant's Fourth Amendment rights. View "State v. Salcedo" on Justia Law

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Plaintiff, the former CEO of Alabama One Credit Union, filed suit under 42 U.S.C. 1983 against the Governor of Alabama and his legal advisor, alleging that defendants conspired with others to improperly exert regulatory pressure on the credit union in order to induce Alabama One to settle lawsuits brought by a friend and former law partner of the legal advisor. The Eleventh Circuit affirmed the district court's dismissal of the complaint, holding that plaintiff failed to plausibly allege that the Governor or his legal advisor was responsible for causing his injuries. Even if the court could assume away the basic causation problem, the court held that plaintiff failed to plausibly allege that defendants violated his clearly established constitutional rights. Accordingly, defendants were entitled to qualified immunity and the district court did not err in dismissing the complaint. View "Carruth v. Bentley" on Justia Law

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Jack and Angela Howser decided that Angela’s estranged daughter, Jade, was failing to provide a suitable home for Jade’s four-year-old daughter, E.W. After unsuccessfully attempting to blackmail Jade, they enlisted the local police, the sheriff’s office, the county prosecutor, and a private investigator to help them. The group agreed that they would arrest Jade while Jade’s husband (Josh) was out of the house so that the Howsers could take the child. After midnight on Sunday night, a caravan of the sheriff, a deputy, the Howsers, and the private investigator set out for Jade’s home to arrest her for writing Angela a $200 check that had bounced. Once Jade was in handcuffs, an officer gave Jack the all-clear to come inside. The sheriff did not allow Jade to designate a custodian for E.W. or obtain her consent to giving E.W. to the Howsers. Jade sued the Howsers under 42 U.S.C. 1983 for conspiring with state officials to violate her due process right to make decisions regarding the care, custody, and control of her child. A jury returned a verdict in her favor. The Seventh Circuit affirmed, finding sufficient evidence to support the verdict and upholding the magistrate judge’s pretrial decision to exclude unfavorable information about Jade and Josh. The court upheld an award of $970,000 in damages. View "Green v. Howser" on Justia Law