Justia Civil Rights Opinion Summaries

by
The Fourth Circuit affirmed the district court's grant of a declaratory judgment holding that the clerks from two Virginia courts, that failed to make newly filed civil complaints timely available to the press and public, violated the First Amendment right of access to such documents.As a preliminary matter, the court concluded that this case is not moot where, absent the relief Courthouse News sought, nothing bars the clerks from reverting to the allegedly unconstitutional rates of access in the future; the district court did not abuse its discretion in denying the clerks' motion to abstain; and the district court did not abuse its discretion in denying the clerks' motion to dismiss for misjoinder.On the merits, the court applied the experience and logic test to Courthouse News' First Amendment right of access claim, concluding that the experience prong supports a First Amendment right of access to civil complaints, even before any judicial action in the case, and that public access to complaints logically plays a positive role in the functioning of the judicial process. Therefore, the press and public enjoy a First Amendment right of access to newly filed civil complaints. The court agreed with the district court's determination that the clerks violated Courthouse News' right of access to newly filed civil complaints. View "Courthouse News Service v. Schaefer" on Justia Law

by
Plaintiffs moved to enjoin implementation of the Aerial Investigation Research (AIR) program, a first-of-its-kind aerial surveillance program operated by the Baltimore Police Department and Commissioner Michael Harrison. While appeal was pending, the program completed its pilot run and the program was not renewed. After deleting the bulk of the AIR data, defendants moved to dismiss the appeal as moot.On rehearing en banc, the court concluded that the appeal presents a live controversy and is not moot. Plaintiffs sought to enjoin defendants' access to any data collected by the AIR program, and defendants retain the data that proved fruitful. In this case, plaintiffs have a concrete, legally cognizable interest in freezing the police department's access to images, which were obtained only by recording plaintiffs' movements and in which they may still appear.On the merits, the court concluded that plaintiffs are likely to succeed on the merits of their Fourth Amendment claim and the remaining Winter factors counsel in favor of preliminary relief. The court applied Carpenter v. United States, 138 S. Ct. 2206 (2018), concluding that the AIR program enables police to deduce from the whole of individuals' movements, and thus accessing its data is a search, and its warrantless operation violates the Fourth Amendment. The court reversed the denial of plaintiffs' motion for a preliminary injunction and remanded for further proceedings. View "Leaders of a Beautiful Struggle v. Baltimore Police Department" on Justia Law

by
The Supreme Court affirmed the judgment of the superior court convicting Defendant of five counts related to conduct stemming from a drive-by shooting, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) there was no need to reach the merits of Defendant's belatedly raised double jeopardy contention; (2) the trial justice did not err in denying Defendant's motion to suppress an eyewitness identification; (3) the trial justice did not err by summarily denying Defendant's motion to recuse; (4) Defendant was not denied his constitutional right to self-representation; and (5) Defendant's remaining arguments were not properly preserved for appellate review. View "State v. Segrain" on Justia Law

by
The Supreme Court affirmed the sentence of death that was imposed at Defendant's resentencing for the first-degree murder of Seath Jackson, holding that Defendant's claims of error were unavailing.The Supreme Court previously affirmed Defendant's conviction for first-degree murder with a firearm but vacated his sentence of death and remanded for a new penalty phase based on Hurst v. State, 202 So. 3d 40 (Fla. 2016). After a new penalty phase, the judge again imposed a sentence of death. The Supreme Court affirmed, holding (1) the State was not precluded from seeking the death penalty; (2) Defendant's argument that the court erred in allowing evidence of post-death acts was not adequately preserved for review; (3) the circuit court did not abuse its discretion in assigning little or no weight to mental mitigation factors; (4) the circuit court properly considered Defendant's age and certain other mitigating circumstances; and (5) the death sentence was not disproportionate. View "Bargo v. State" on Justia Law

by
The Supreme Court reversed the judgment of the court of appeals upholding the order of the municipal court granting Defendant's motion to suppress, holding that the police officer's investigatory stop of Defendant was reasonable and thus did not violate the Fourth Amendment.At issue was whether the officer had reasonable suspicion to briefly detain Defendant in order to confirm or dispel an unidentified witness's claim that Defendant was operating a motor vehicle while intoxicated. The trial court granted Defendant's motion to suppress. The court of appeals affirmed, holding that the officer lacked the reasonable suspicion necessary to effectuate a lawful investigatory stop because the anonymous tip lacked sufficient indicia of reliability and because there was no evidence of erratic driving by Defendant prior to the stop. The Supreme Court reversed, holding that the officer had reasonable suspicion to investigate whether Defendant was driving while drunk based on the unidentified customer's tip and the officer's own partial corroboration of that tip. View "State v. Tidwell" on Justia Law

by
Plaintiff appealed the dismissal of his 42 U.S.C. 1983 claims based on allegations that defendants illegally extradited him from Pennsylvania to Louisiana and impermissibly extended his state sentence by thirty years. Plaintiff's claims arose from a records clerk's reversion of his release date to the 2052 date, rather than the 2023 date, on the grounds that he had stopped serving his state sentence when he escaped from prison and that his state and federal sentences were intended to run consecutively.The Fifth Circuit affirmed the district court's dismissal of plaintiff's sentence-based claims, but reversed and remanded with respect to the extradition-based claims. The court held that Heck v. Humphrey, 512 U.S. 477 (1994), does not present a jurisdictional hurdle that would require a remand of this case to state court. The court explained that Heck implicates a plaintiff's ability to state a claim, not whether the court has jurisdiction over that claim. As to plaintiff's claim regarding his sentence enhancement, the court concluded that a claim for speedier release is actionable by writ of habeas corpus, and a section 1983 damages action predicated on the sentence calculation issue is barred by Heck because success on that claim would necessarily invalidate the duration of his incarceration. The court also concluded that the district court never analyzed whether plaintiff's extradition-based claims were barred by Heck, and the district court should have considered whether his extradition-based claims survived Heck in the first instance. Furthermore, the district court should consider the qualified immunity, absolute immunity, and limitations ruling issues on remand. The court vacated in part and remanded for further proceedings. View "Colvin v. LeBlanc" on Justia Law

by
Daza worked as a geologist for INDOT from 1993 until the agency fired him in 2015. In 2017, he sued, citing 42 U.S.C. 1981 and 1983, the First and Fourteenth Amendments, the Age Discrimination in Employment Act, 29 U.S.C. 621, and the Americans with Disabilities Act, 42 U.S.C. 12101. He alleged that INDOT and its officials had discriminated against him based on race, color, age, and political speech and had retaliated against complaints he made regarding the alleged discrimination.Days after the district court granted INDOT summary judgment in 2018, Daza filed a second action, again alleging discrimination and retaliation based on race, color, age, and political speech, contending that INDOT’s failure to rehire him for the vacancy left after INDOT dismissed him was an independent act of discrimination and retaliation because INDOT filled his position with a young and inexperienced white man. In the first suit, Daza had expressly contended that INDOT’s failure to rehire him and its decision to hire an unqualified replacement proved that INDOT was attempting to cover up its discrimination and retaliation. The Seventh Circuit again affirmed summary judgment in favor of INDOT. Claim preclusion barred the second case. View "Daza v. Indiana" on Justia Law

by
Five former employees of national security agencies who, during their employment, had clearances for access to classified and sensitive information, filed suit against the CIA, the Department of Defense, the National Security Agency, and the Office of the Director of National Intelligence. They facially challenged the agencies’ requirements that current and former employees give the agencies prepublication review of certain materials that they intend to publish to allow the agencies to redact information that is classified or otherwise sensitive to national security. They alleged that the agencies’ regimes “fail to provide former government employees with fair notice of what they must submit,” “invest executive officers with sweeping discretion to suppress speech[,] and fail to include procedural safeguards designed to avoid the dangers of a censorship system.”The Fourth Circuit affirmed the dismissal of the suit, holding that the prepublication review regimes were “reasonable” measures to protect sensitive information and did not violate the plaintiffs’ First Amendment rights. The regimes were not unduly vague under the Fifth Amendment; they adequately informed authors of the types of materials they must submit and established for agency reviewers the kinds of information that can be redacted. View "Edgar v. Haines" on Justia Law

by
In 2007, Crawley and two codefendants invaded a home and attacked and robbed a man they believed to be a drug dealer. A woman and two children were also in the home. Crawley pleaded guilty to conspiracy to commit Hobbs Act robbery, 18 U.S.C. 1951 and using, carrying, and brandishing firearms during and in relation to a crime of violence and a drug trafficking crime, 18 U.S.C. 924(c). Other counts were dismissed, including for attempting to possess with intent to distribute a Schedule II Controlled Substance, 21 U.S.C. 846. The court sentenced Crawley to 150 months on Count One and 84 months on Count Three, to run consecutively. Crawley later unsuccessfully moved to vacate his sentence under 28 U.S.C. 2255.The Fourth Circuit subsequently permitted Crawley to file a second 2255 motion challenging his 924(c) conviction and sentence in light of the Supreme Court’s 2015 holding that the residual clause of the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(2)(B)(ii), is unconstitutionally vague. While Crawley’s motion was pending, the Fourth Circuit concluded that conspiracy to commit Hobbs Act robbery is not a crime of violence under section 924(c)’s force clause and the crime of violence definition in section 924(c)’s residual clause is unconstitutionally vague. The Fourth Circuit affirmed that Crawley’s 924(c) conviction remained valid because it was predicated on the use, carrying, and brandishing of firearms during the charged drug trafficking crime. View "United States v. Crawley" on Justia Law

by
The Fifth Circuit withdrew its prior opinion on April 21, 2021 and substituted the following opinion.After petitioner was convicted of capital murder in Texas and sentenced to death, on federal habeas corpus review, the district court granted him relief. The Fifth Circuit court then affirmed the grant of relief, petitioner was retried, and petitioner was resentenced to death. Petitioner again sought federal habeas corpus relief under 28 U.S.C. 2254, but the district court denied relief on all claims.The Fifth Circuit denied petitioner a certificate of appealability (COA) on the issue of whether the admission of testimony from a defense expert was fruit of the poisonous tree where petitioner has not identified any clearly established Supreme Court precedent extending Harrison v. United States, 392 U.S. 219 (1968), to his incriminating statements to his own expert; whether the State's peremptory strike of a black juror violated petitioner's right to a fair and impartial trial under Batson v. Kentucky, 476 U.S. 79 (1986), where the prosecutor gave six reasons for striking the juror and petitioner failed to present clear and convincing evidence to rebut the determination as objectively unreasonable; whether the State suppressed evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), where he failed to establish cause for defaulting his Brady claim; and (4) whether petitioner received ineffective assistance of trial, appellate, and habeas counsel under Strickland v. Washington, 466 U.S. 668 (1984), where he failed to prove either the deficiency prong and/or prejudice prong of Strickland and thus could not overcome the procedural bar. View "Guidry v. Lumpkin" on Justia Law