Justia Civil Rights Opinion Summaries

Officer Francisko, checking hunters’ licenses, approached a van parked on the side of a road. Armed hunters had just emerged from the woods. The driver, Cataline, was acting strangely but handed Francisko his driver’s license. While Francisko was doing a license check, Cataline called 911 and said: “I am in a lot of trouble … I think I am going to be disappearing.” He then hung up. Francisko told Cataline that he was free to go. The 911 operator reached Officer Kuehl’s supervisor, who told him to stop Cataline to check whether he was fit to drive. The officers followed Cataline’s van, pulled it over, and asked Cataline to turn off the engine. He did not comply but stared straight ahead. After ignoring three requests, Cataline put the van into reverse, turned, and pointed the van west in the eastbound lanes of the Interstate. Cataline then made another turn and plowed the van into the side of Kuehl’s car. Kuehl and Francisko say that Kuehl was pinned behind the door. Francisko shot Cataline, who died at the scene. The district court granted the defendants summary judgment in a suit under 42 U.S.C. 1983. The Seventh Circuit affirmed. Cataline’s behavior and the odd 911 call would have led an officer to be concerned that he posed a danger to himself and others. Francisko and Kuehl testified that they saw the van cross the white line on the highway several times. The stop was reasonable and compatible with the Fourth Amendment. View "Gysan v. Francisko" on Justia Law

Brown, a detainee at Wisconsin’s Polk County Jail, underwent a physical search of her body cavities. The institution had a written policy authorizing such a search to be conducted by medical personnel when there was reasonable suspicion to believe an inmate was internally hiding contraband. Fellow inmates had reported that Brown was concealing methamphetamine inside her body, which prompted jail staff to invoke the policy. Officers took Brown to a hospital, where a doctor and nurse first conducted an ultrasound, then inspected both her vagina and rectum in a private room without officers present. The search revealed no drugs. Brown sued under 42 U.S.C. 1983, alleging violation of her Fourth Amendment rights. The district court granted the defendants summary judgment. The Seventh Circuit affirmed. The defendants had reasonable suspicion that Brown was concealing contraband, their suspicion justified the cavity search, and the ensuing search was reasonable. View "Brown v. Polk County" on Justia Law

Marling was arrested while driving his car. Police took an inventory. The trunk held a locked box. An officer opened the box with a screwdriver and found illegal drugs. Marling was armed, despite felony convictions. After unsuccessfully moving to suppress the box's contents, Marling received a 38-year sentence, as a habitual criminal. He filed an unsuccessful state court collateral attack, arguing that his lawyers furnished ineffective assistance by not arguing that opening the box damaged the box, in violation of police policy. The court of appeals found that the record did not establish damage to the box. A federal district court issued a writ of habeas corpus, ruling that a photograph showed damage to the box. The Seventh Circuit reversed. A factual mistake by a state court does not support collateral relief unless a correction shows that the petitioner “is in custody in violation of the Constitution or laws or treaties” of the U.S. Not every departure from any policy violates the Fourth Amendment. The policy at issue states an officer “should avoid” opening a container when that would cause “unreasonable potential damage.” The policy is valid: it combines a presumptive rule of opening everything with a discretionary exception. Because the policy is valid, the search is valid. A district judge’s disagreement about whether the officer followed the local policy is not a sufficient ground for collateral relief. View "Marling v. Brown" on Justia Law

The Eleventh Circuit affirmed the district court's judgment and denial of habeas relief to petitioner. Petitioner was convicted of capital murder for leaving an elderly woman in the hot trunk of a car, where she eventually suffered a heart attack and died, after robbing her. The court held that the state court's determination that petitioner's counsel was not encumbered by an actual conflict that adversely affected his performance was neither contrary to nor an unreasonable application of clearly established law or an unreasonable determination of the facts. The court also held that the petition failed to establish ineffective assistance of counsel during the penalty phase of his capital trial where his lawyers failed to adequately investigate and present mitigating evidence, because petitioner failed to establish prejudice. View "Dallas v. Warden" on Justia Law

Plaintiff filed suit against two officers, alleging claims of malicious prosecution under both the Fourth Amendment and Alabama law. After plaintiff was shot by one of the officers and spent two months in a hospital recovering, he spent more than 16 months in pretrial detention on charges of attempted murder. The charges were eventually dropped when a news organization eventually published a video recorded on a dashboard camera that supported plaintiff's account that he had dropped his gun and complied with the officers' commands. The Eleventh Circuit affirmed the district court's denial of summary judgment based on qualified immunity to the officers. The court held that the record presents a genuine dispute of fact about whether plaintiff's pretrial detention was unlawful where, regardless of its applicability to warrantless arrests, the any-crime rule does not apply to claims of malicious prosecution under the Fourth Amendment; malicious prosecution requires plaintiff to prove that the judicial determination of probable cause underlying his seizure was invalid; and plaintiff has established a genuine issue of fact over whether he suffered an unconstitutional seizure pursuant to legal process. Furthermore, the officers caused plaintiff's injury and plaintiff had a clearly established right to not be seized based on intentional and material misrepresentations in a warrant application. The court also held that the officers are not entitled to state-agent immunity because a genuine dispute of fact exists about whether the officers acted maliciously. View "Williams v. Aguirre" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder and other crimes and sentence of death, holding that there was no prejudicial error in the trial proceedings. Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to suppress evidence seized during a warrantless probation search of his home; (2) the trial court did not abuse its discretion in denying Defendant's motion to sever the capital charges from his remaining charges; (3) the evidence was sufficient to support the convictions; (4) Defendant's challenges to the trial court's guilt phase instructions lacked merit; (5) a failure of consular notification under the Vienna Convention occurred in this case, but no prejudice resulted from it; (6) the trial court did not err in denying Defendant's motion to modify the verdict; and (7) Defendant's challenges to California's death penalty law were unavailing. View "People v. Vargas" on Justia Law

Plaintiff filed suit alleging a sex discrimination claim for a failure to promote against the County of Wright and the Wright County Sheriff's Department under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA). The Eighth Circuit affirmed the district court's grant of summary judgment to the County, holding that plaintiff failed to present evidence that one of the reasons for the chief deputy's actions in not promoting plaintiff was gender animus; plaintiff failed to argue that the interview notes show that the other panelists' negative impressions of her were pretextual, or that the chief deputy was somehow responsible for their negative impressions; and plaintiff failed to point to any evidence of gender animus from the other panelists. The court also held that the district court did not err by concluding that plaintiff failed to raise a genuine issue of material fact as to her cat's-paw theory. View "Pribyl v. County of Wright" on Justia Law

After plaintiff was injured while performing work in the Adult Offender Work Program (AOWP), he filed suit against the county for its failure to accommodate his preexisting physical disability and failure to engage in the interactive process under the Fair Employment and Housing Act (FEHA). The Court of Appeal affirmed the trial court's grant of summary judgment in favor of the county. The court held that an individual sentenced to perform work activities in lieu of incarceration in the absence of any financial remuneration, is precluded, as a matter of law, from being an "employee" within the meaning of the FEHA. The court explained that, while remuneration alone is not a sufficient condition to establish an individual is an employee under the statute, it is an essential one. Because plaintiff earned no sufficient financial remuneration as a result of participation in the AOWP, he could not be deemed an employee under the FEHA. The court did not reach plaintiff's remaining arguments. View "Talley v. County of Fresno" on Justia Law

In 1996, Lee and Kehoe, members of a white supremacist organization, traveled from Washington to the Arkansas home of Mueller, a firearms dealer. After stealing about $30,000 worth of weapons and $50,000 in cash and coins, the two stunned Mueller, his wife, and his eight-year-old daughter and sealed plastic bags over their heads, then threw them into the Illinois Bayou. The bodies were discovered months later. The two were convicted under 18 U.S.C. 1959(a)(1). Kehoe’s jury returned a verdict of life in prison. At Lee’s sentencing, prosecutors introduced evidence of his involvement in a 1990 Oklahoma murder; the government’s expert testified that Lee had a test score in the psychopathy range. The Eighth Circuit affirmed Lee’s death sentence. Lee pursued collateral review. The government scheduled Lee’s execution for December 2019. He again sought relief. The district court stayed Lee’s execution. The Seventh Circuit vacated the stay, stating that Lee’s likelihood of success on the merits was “slim” because both claims—Brady claims alleging suppression of exculpatory evidence and Strickland claims alleging ineffective assistance of counsel—are “regularly made and resolved under section 2255,” so the remedy cannot be called “inadequate or ineffective” for purposes of the Savings Clause in section 2241. The evidence Lee claims is “newly discovered” was known to him and publicly available in the court record of his Oklahoma murder case. Lee’s execution was rescheduled for July 13, 2020. The judge denied Lee’s Rule 59 motion. The Seventh Circuit denied relief, finding Lee’s arguments frivolous. View "Lee v. Watson" on Justia Law

Plaintiff filed suit against various correctional officials under 42 U.S.C. 1983, alleging a violation of his procedural due process rights. Plaintiff's claims stemmed from the four years that he spent in solitary confinement in prison. The district court granted summary judgment to the officials on the ground that plaintiff had failed to establish a protected liberty interest. The Fourth Circuit vacated and held that plaintiff has presented evidence demonstrating that his confinement conditions were severe in comparison to those that exist in general population and that his segregation status may have had collateral consequences relating to the length of his sentence. Furthermore, although the duration of plaintiff's segregated confinement is not as long as the substantial periods of segregated confinement that this court has found sufficient to support a protected liberty interest in the past, prisoners need not languish in solitary confinement for decades on end in order to possess a cognizable liberty interest under the Due Process Clause of the Fourteenth Amendment. In this case, the four-plus years that plaintiff spent in administrative segregation is significant enough to tip the scales in his favor, particularly in light of the other evidence of indefiniteness that he relies upon in this case. Therefore, the court held that there is at least a genuine dispute of material fact as to whether plaintiff's conditions of confinement imposed a significant and atypical hardship in relation to the ordinary incidents of prison life. The court remanded for further proceedings. View "Smith v. Collins" on Justia Law