Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the court of criminal appeals affirming Defendant's conviction for burglary, holding that application of the burglary statute under the circumstances of this case did not violate due process or prosecutorial discretion. Defendant's conviction arose from her involvement in a scheme to enter a Walmart retail store, steal merchandise, and have another individual return the merchandise for a gift card. Defendant had previously been banned from Walmart retail stores for prior acts of shoplifting, and the owners of these stores had issued documents to Defendant precluding Defendant from entering the stores. The State sought an indictment against Defendant for burglary rather than criminal trespass, reasoning that Defendant entered Walmart without the effective consent of the owner and committed a theft therein. Defendant appealed her burglary conviction, arguing that the burglary statute is unconstitutionally vague as applied to the extent that it implicates due process rights. The Supreme Court affirmed, holding (1) the language of the statute criminalizing burglary is clear and unambiguous on its face; (2) the statute is not unconstitutionally vague as applied, and nothing in the statute precludes its application to the fact scenario in this case; and (3) the prosecutor did not exceed her discretion in interpreting and applying the statute. View "State v. Welch" on Justia Law

Relying on an earlier decision (Rabun County), the Eleventh Circuit affirmed a decision ordering the removal of a 34-foot Latin cross from the City of Pensacola’s Bayview Park, finding that the maintenance of the cross violated the First Amendment’s Establishment Clause. While the city's petition for certiorari was pending, the Supreme Court held, in "American Legion," that a 32-foot Latin cross on public land in Bladensburg, Maryland does not violate the Establishment Clause. The Supreme Court vacated the earlier decision and remanded for further consideration in light of American Legion. On remand, the Eleventh Circuit concluded that it remains bound by Rabun to conclude that plaintiffs have Article III standing to challenge Pensacola’s maintenance of the cross but that American Legion abrogates Rabun to the extent that the latter disregarded evidence of “historical acceptance.” When "American Legion" is applied, the cross’s presence on city property does not violate the Establishment Clause. The Bayview cross (in one iteration or another) stood in the same location for more than 75 years; there is no evidence of the city's original purpose in its placement. The message and purposes of the cross have changed over time. A strong presumption of constitutionality” attaches to “established” monuments, View "Kondrat'yev v. City of Pensacola," on Justia Law

Bridges, a Cook County Department of Corrections pretrial detainee, fell out of the upper bunk to which he had been assigned and injured himself. He sued, asserting that his injuries were caused by the defendants’ practice of ignoring medically necessary lower bunk prescriptions. Bridges cited five lawsuits filed by detainees who alleged that, between 2005 and 2012, they were injured when using upper bunks after their lower bunk prescriptions were ignored. The Seventh Circuit affirmed summary judgment in favor of the defendants. A local government may not be sued under 42 U.S.C. 1983 for an injury inflicted solely by its employees or agents; it is when the execution of a government’s policy or custom, whether made by its lawmakers or by those whose edicts or acts may fairly be said to represent official policy, inflicts the injury that the governmental entity is responsible under section 1983. The Department houses thousands of detainees, with hundreds entering and leaving on a daily basis; three or five incidents over a seven-year period is inadequate as a matter of law to demonstrate a widespread custom or practice. Nothing connected the incidents and they were not so common as to place the defendants on notice of a widespread practice. View "Bridges v. Dart" on Justia Law

Fourstar, a federal prisoner, filed a Tucker Act Complaint with a Motion for Leave to Proceed In Forma Pauperis. He claimed that the government is mismanaging certain Indian properties and resources. The Claims Court denied his motion to proceed in forma pauperis, citing 28 U.S.C. 1915(g), which provides: In no event shall a prisoner bring a civil action or appeal ... under this section if the prisoner has, on 3 or more prior occasions, while incarcerated or detained in any facility, brought an action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted, unless the prisoner is under imminent danger of serious physical injury,” Prison Litigation Reform Act, 110 Stat. 1321. Fourstar did not pay the filing fee. The court dismissed his complaint. Fourstar was released from prison and later filed a Notice of Appeal. He later filed a statement that he was subsequently arrested and detained and unsuccessfully moved to proceed in forma pauperis on appeal. Because Fourstar was not a prisoner at the time of filing his appeal, section 1915 is not applicable. The Federal Circuit affirmed that the three-strikes rule was met by Fourstar’s litigation history and that Fourstar was not subject to the “imminent danger” exception. View "Fourstar v. United States" on Justia Law

Ali shot and killed three people during an attempted robbery in Minneapolis. He was given three consecutive life sentences, each permitting his early release after 30 years so that Ali must remain in prison for at least 90 years. Relying on recent Supreme Court precedent, Ali argued that the Eighth Amendment forbids life-without-parole sentences for juvenile defendants unless they are irreparably corrupt and that a sentencing court must conduct a hearing to consider the juvenile defendant’s youth as a mitigating factor before imposing a life-without-parole sentence. Ali claimed his sentence was the “functional equivalent” of life-without-parole. The Minnesota Supreme Court rejected Ali’s argument. The Eighth Circuit affirmed the denial of Ali’s petition for habeas relief under 28 U.S.C. 2254. Ali’s case is distinguishable from the Supreme Court cases; Ali received three life sentences for three separate murders, each permitting possible release. Ali does not face a life-without-parole sentence and the Supreme Court has not “clearly established” that its ruling apply to consecutive sentences functionally equivalent to life-without-parole. View "Ali v. Roy" on Justia Law

In 2018, Florida voters approved Amendment 4, a state constitutional amendment that automatically restored voting rights to ex-felons who had completed all of the terms of their sentences. Plaintiffs filed suit challenging the constitutionality of the "legal financial obligation" (LFO) requirement in Senate Bill 7066, which implemented the Amendment and interpreted its language to require payment of all fines, fees and restitution imposed as part of the sentence. The district court ultimately issued a preliminary injunction requiring the state to allow the named plaintiffs to register and vote if they are able to show that they are genuinely unable to pay their LFOs and would otherwise be eligible to vote under Amendment 4. The state appealed. The Eleventh Circuit held that the LFO requirement violates the Equal Protection Clause of the Fourteenth Amendment as applied to these plaintiffs. The court stated that it was undeniable that the LFO requirement punishes those who cannot pay more harshly than those who can, and denying access to the franchise to those genuinely unable to pay solely on account of wealth does not survive heightened scrutiny. The court also held that the district court did not abuse its considerable discretion in balancing the equitable factors for a preliminary injunction. Furthermore, under Florida law the unconstitutional application of the LFO requirement was easily severable from the remainder of Amendment 4. Accordingly, the court affirmed the preliminary injunction entered by the district court. View "Jones v. Governor of Florida" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that reasonable parental discipline is not a component of the physical-harm element on Ohio's domestic violence and assault statues but, rather, is an affirmative defense to a charge under those statutes, holding that reasonable parental discipline is an affirmative defense. Defendant was charged with one third-degree felony count of domestic violence and one first-degree misdemeanor count of assault for allegedly beating the seven-year-old son of his live-in girlfriend for acting out at school. During trial, Defendant argued that his conduct was a reasonable exercise of parental discipline and corporal punishment. The trial court found Defendant guilty of the charges. The court of appeals affirmed, holding that treating reasonable parental discipline as an affirmative defense and placing the burden of proving that defense upon the accused does not violate due process. The Supreme Court affirmed, holding (1) proof of unreasonable parental discipline is not a component of the physical harm element of the offenses; (2) reasonable parental disciplines an affirmative defense; and (3) treating reasonable parental discipline as an affirmative defense does not unconstitutionally place the burden of proof on the defendant. View "State v. Faggs" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, conspiracy to commit murder, and related crimes, holding that any violation of Defendant's right to confrontation was harmless and that the trial court's third-party culpability instruction was sufficient. Defendant's convictions arose from a shooting on a crowded street in which a fifteen-year-old boy died and two individuals were seriously injured. The Supreme Court affirmed the convictions, holding (1) as to Defendant's argument that the trial court erred in admitting the out-of-court statements of two witnesses identifying Defendant as the shooter, Defendant failed to preserve his hearsay objection, and even if the admission of the out-of-court identifications violated Defendant's right to confrontation, any error was harmless beyond a reasonable doubt; and (2) the trial court's third-party culpability instruction was sufficient despite the fact that the instruction omitted certain names. View "State v. Edwards" on Justia Law

The Mississippi Board of Licensure for Professional Engineers and Surveyors filed suit against Vizaline to enjoin its business and disgorge its profits. Vizaline then filed suit against the Board, alleging that as applied to its practice, Mississippi's surveyor-licensing requirements violate the First Amendment. The district court dismissed Vizaline's suit. The Fifth Circuit reversed, holding that the district court's ruling -- that Mississippi's licensing requirements for surveyors do not trigger any First Amendment scrutiny -- was inconsistent with the Supreme Court's recent decision in Nat'l Inst. of Family & Life Advocates v. Becerra [NIFLA], 138 S. Ct. 2361, 2375 (2018). NIFLA disavowed the notion that occupational-licensing regulations are exempt from First Amendment scrutiny. Therefore, the district court erred by categorically exempting occupational-licensing requirements from First Amendment scrutiny. The court remanded for further proceedings. View "Vizaline, LLC v. Tracy" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment on Appellant's federal law claims under the Age Discrimination and Employment Act, and on the state-law claims for discrimination, retaliation based on a complaint of age discrimination, and failure to investigate and vacated the summary judgment on the state law claims for retaliation based on a report of gender discrimination, breach of contract, intentional interference with contractual relations, and defamation, holding that the court erred in granting summary judgment as to these claims. This lawsuit arose from events that led to Appellant's retirement from his position as Fire Chief for the Fire Department of the Town of Marshfield, Massachusetts. The district court granted summary judgment in favor of the Town on all of Appellant's federal and state law claims. The First Circuit affirmed in part and vacated in part, holding (1) summary judgment was properly granted as to some of Appellant's claims; but (2) as to the remaining state law claims, there was no analogue to the common law claims in the federal law claims that were addressed, and rather than attempt to resolve the state law issues that were in dispute as to these claims, their dismissal was directed without prejudice. View "Robinson v. Town of Marshfield" on Justia Law