Justia Civil Rights Opinion Summaries

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Donald has glaucoma and keratoconus, a thinning of the cornea that causes distorted vision. To treat his keratoconus, Donald had left-eye corneal transplant surgery in 2011. A few years later, Donald was convicted of drug crimes. He began his prison sentence at Illinois River Correctional Facility in 2014. His eye problems started flaring up, causing redness and poor vision. He was subsequently seen by Illinois River’s optometrists and at Illinois Eye Center several times. Ultimately, he was diagnosed with a rupture of the globe, an irreversible loss of vision in his left eye. After surgery, pathological tests revealed that the infection that led to the ruptured globe was caused by bacteria that can act very quickly and cause perforation in as few as 72 hours. Donald filed suit under 42 U.S.C. 1983 for deliberate indifference to a serious medical need.The district court granted the defendants summary judgment. The Seventh Circuit affirmed. The undisputed evidence shows that the defendants did not act with deliberate indifference toward an objectively serious medical condition and the district court appropriately exercised supplemental jurisdiction to dispose of the malpractice claim. View "Donald v. Wexford Health Sources, Inc." on Justia Law

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Plaintiff filed suit against various parties under 42 U.S.C. 1983, asserting a violation of his Fourteenth Amendment right to due process after the police department destroyed some of his firearms by smelting them. The district court granted summary judgment in favor of the defendants sued in their individual capacities. The district court also concluded that plaintiff could not maintain his Monell failure-to-train claim against the municipal defendants and granted summary judgment in favor of them.The Ninth Circuit held that a rational trier of fact could find that plaintiff's due process rights were violated when his firearms were seized and destroyed. In this case, given the fact that plaintiff continued to assert a claim of right to the firearms and reasonably believed that the LAPD was still reviewing the documentation he provided, he was entitled to know that the LAPD intended to seek an order permitting destruction of the remaining firearms at issue. A reasonable jury could find that plaintiff was entitled to notice, and Officer Edwards, who filed the application for an order to destroy the firearms and failed to provide plaintiff with notice, violated plaintiff's due process rights. Furthermore, the panel had no doubt that Officer Edwards had fair notice that his conduct violated plaintiff's due process right to notice, and thus Officer Edwards was not entitled to qualified immunity. Accordingly, the panel reversed the district court's grant of summary judgment on this claim. The panel also reversed plaintiff's Monell failure-to-train claim against Defendants Beck, Feuer, and the City. The panel affirmed the judgment as to Defendants Aubry and Tompkins, remanding for further proceedings. View "Wright v. Beck" on Justia Law

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In 2001, Penn State’s former president, Spanier, and others decided not to report to state authorities suspected sexual abuse of children involving the school’s football program and Jerry Sandusky, the well-known defensive coordinator for Penn State’s football team. In 2007, Pennsylvania amended the statutory definition of child endangerment and its statute of limitations. In 2012, Spanier was charged. The jury was instructed in language that tracked the post-amendment statute. The Commonwealth argued that Spanier engaged in a course of conduct endangering child welfare until 2012, and therefore he “was charged well within the applicable statute of limitation.” In affirming Spanier’s 2017 conviction, the state court concluded that Spanier's conduct violated the 1995 statute as interpreted by the Pennsylvania Supreme Court in 2015. The federal district court granted Spanier’s federal habeas corpus petition and vacated his conviction.The Third Circuit reversed. The Pennsylvania court’s affirmance of Spanier’s conviction, based on its conclusion that his conduct was covered by the 1995 statute was not “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court.” While that court applied state supreme court precedent post-dating the conduct in question, the supreme court’s interpretation of the statute was not unforeseeable nor indefensible. View "Spanier v. Director Dauphin County Probation Services" on Justia Law

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In 2016, Officers Brandon Vick and Josh Girdner shot and killed Dominic Rollice. The administrator of Dominic’s estate brought a section 1983 claim against Officers Vick and Girdner, alleging they used excessive force against Dominic in violation of his Fourth Amendment rights. The district court granted summary judgment to Officers Vick and Girdner on the basis of qualified immunity. The estate appealed. Finding a reasonable jury could have found facts under which Officers Vick and Girdner would not be entitled to qualified immunity, the Tenth Circuit reversed judgment and remanded for further proceedings. View "Bond v. City of Tahlequah" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of "dealing in a look-a-like substance," a level five felony under Ind. Code 35-48-4-4.6, holding that trial court did not err in denying Defendant's motion to suppress.At a casino, Defendant offered to sell a substance to a stranger, who reported the incident. Thereafter, a Gaming Enforcement Agent led Defendant to an interview room and proceeded to pat him down. The trial court admitted the evidence discovered as a result of the pat down. The Supreme Court affirmed, holding (1) the search and seizure proceeded within the bounds of the Fourth Amendment; and (2) therefore, the trial court did not abuse its discretion in admitting evidence obtained as a result. View "Johnson v. State" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, assault and battery by means of a dangerous weapon, and improper disposition of a human body, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that the trial court erred in denying his motion to suppress his cell site information (CSLI) because it was obtained by police without a warrant and that a subsequent search pursuant to a warrant for the same information was tainted by the initial warrantless search. The Supreme Judicial Court disagreed, holding (1) the trial judge did not err in failing to suppress Defendant's CSLI, and the motion judge did not err in denying Defendant's motion for a new trial and for an evidentiary hearing on this same basis; (2) trial counsel's failure to move to suppress the fruits of the initial illegal search did not result in a substantial likelihood of a miscarriage of justice; and (3) there was no reason to grant a new trial or set aside the jury's verdict under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Wilson" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of felony murder, with armed robbery as the predicate felony, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge did not err by not providing, sua sponte, an instruction on felony murder in the second degree; (2) the admission of Defendant's cell site location information did not result in a substantial likelihood of a miscarriage of justice; (3) the trial judge did not err in denying Defendant's motion to admit privileged psychiatric records; (4) there was no prejudicial error in the judge's decision prohibiting Defendant from eliciting certain testimony as hearsay on cross-examination; (5) the judge did not err in instructing the jury on inferences; (6) trial counsel provided effective assistance; and (7) there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce Defendant's verdict or order a new trial. View "Commonwealth v. Chesko" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree on a theory of deliberate premeditation and unlawful possession of a firearm, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that his trial counsel provided ineffective assistance, that the judge erred in allowing the introduction of certain evidence, and that the judge abused his discretion in allowing the prosecutor to exercise a peremptory challenge. The Supreme Judicial Court affirmed, holding (1) Defendant did not receive ineffective assistance of counsel; (2) there was no reversible error from the admission of the challenged evidence; (3) there was no abuse of discretion in the judge's finding that Defendant did not establish a prima facie case of excluding black jurors; and (4) there was no basis for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Henderson" on Justia Law

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In 2016 agents found Barrett with nearly 15,000 images and 2,450 videos of child pornography. A search of his computer also uncovered a “Pedophile’s Handbook.” Barrett pled guilty to possessing child pornography under a plea agreement with a provision waiving any appellate challenge “on any ground” to “all components” of his sentence. Barrett confirmed that he understood the waiver during his plea colloquy. The district court sentenced Barrett to 97 months’ imprisonment followed by 10 years of supervised release. Barrett brought a First Amendment challenge to “Condition 31” of supervised release that will prevent him from viewing any material depicting “sexually explicit conduct,” defined in 18 U.S.C. 2256(2) to include adult pornography.The Seventh Circuit affirmed Barrett’s sentence, citing its previously-announced “clear and precise rule” that such conduct constitutes waiver, rendering the challenge unreviewable on appeal. Barrett confirmed at sentencing that he received advance notice of all 34 proposed conditions of supervised release and discussed them with his counsel. The district court invited objections; Barrett responded with several. The objections resulted in a colloquy with the judge and ended with rulings on each challenge. Barrett expressed no reservation with and asked no questions about, Condition 31. That Barrett asserts the First Amendment is irrelevant. View "United States v. Barrett" on Justia Law

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The First Circuit affirmed the judgment of the district court granting a Union's motion to dismiss two Hampshire state employees' (Appellants) complaint pursuant to 42 U.S.C. 1983, holding that Appellants' claim based on Janus v. American Federation of State, County & Municipal Employees, Council 31, 138 S. Ct. 2448 (2018), was not cognizable under section 1983.Appellants sought retrospective relief for themselves and other state employees who were not members of the State Employees' Association of New Hampshire (the Union) but were forced to pay "agency fees" to it prior to the decision in Janus. In Janus, the United States Supreme Court overruled its decision in Abood v. Detroit Board of Education, 431 U.S. 209 (1977), and held that "agency fee" arrangements violate the First Amendment. The district court granted the Union's motion to dismiss Appellants' complaint for failure to state a claim. The First Circuit affirmed, holding that the district court correctly held that Appellants' damages claim failed. View "Doughty v. State Employees' Ass'n of New Hampshire" on Justia Law