Justia Civil Rights Opinion Summaries

The U.S. Court of Appeals for the District of Columbia Circuit ruled on an appeal by former President Donald J. Trump regarding his claim of presidential immunity from civil damages liability related to the January 6, 2021, Capitol riot. Plaintiffs included Capitol Police officers and members of Congress who alleged that Trump, through his actions and speech, incited the riot that resulted in physical injuries and emotional distress.The court determined that, at this stage in the proceedings, Trump has not demonstrated an entitlement to presidential immunity. It distinguished between actions carried out in a president’s official capacity, which are protected by immunity, and those carried out in a private or unofficial capacity, which are not. The court rejected Trump's argument that presidential speech on matters of public concern is always an official function, stating that such speech can be either official or unofficial depending on context.The court also rejected Trump's claim that his actions leading up to and on January 6 were official because they were under his Article II duty to "take Care that the Laws be faithfully executed," stating that this claim is not independent of his ability to show that he engaged in the relevant actions in his official capacity as President rather than his unofficial capacity as a presidential candidate.The court held that Trump's actions as alleged in the complaints, if proven to be true, were carried out in his capacity as a presidential candidate, not as the sitting President. Therefore, he is subject to civil suits like any private citizen. However, the court specified that Trump must be allowed to present facts and make arguments in the district court that his actions were taken in his official capacity. View "Blassingame v. Trump" on Justia Law

In a case before the Supreme Court of Iowa, the defendant, Robert Clark Geddes, was charged with trespass as a hate crime. The defendant had trespassed onto various properties, leaving behind anonymous notes that urged the residents to "Burn that gay flag." The homes targeted by the defendant were displaying LGBTQ+ flags or decals. Geddes appealed his conviction, arguing that the evidence was insufficient and that his convictions violated his rights to free speech and due process.The court rejected the defendant's arguments and affirmed his convictions. The court ruled that Geddes was not being punished for his speech, but rather for his conduct—trespassing onto properties with the intent to commit a hate crime. The court found that the statute under which Geddes was convicted does not criminalize speech, but rather conduct with a specific intent—namely, trespassing on property because of the property owner or possessor's association with persons of a certain sexual orientation. The court also found that there was sufficient evidence to support Geddes's conviction.The court held that the defendant's conduct of surreptitiously entering onto properties to post his harassing notes was not protected under the First Amendment rights. The court noted that hate crime laws are designed to punish conduct, not expression, and Geddes's motive or intent led to the more serious criminal consequence. The court also rejected the defendant's argument that the trespass law was vague or overbroad, finding that it provides sufficient guidance to those enforcing it and does not intrude on protected freedoms. View "State of Iowa v. Geddes" on Justia Law

In 2021, the Department of Health and Human Services (HHS) issued a final rule governing the Title X program, which makes grants to assist in the establishment and operation of family planning projects. The Rule interpreted section 1008 of Title X, which bars funds appropriated under the Title X grant program from being “used in programs where abortion is a method of family planning.” States challenged the 2021 Rule’s elimination of a prior HHS rule that required grantees to maintain strict physical and financial separation between Title X programs and abortion-related services they might provide and the Rule’s requirement that Title X projects provide referrals for abortion services when requested by the patient.The Supreme Court has held (“Rust,” 1991) that section 1008 is ambiguous as to program integrity and referrals for abortion and that Chevron deference applies. The Sixth Circuit held Ohio is entitled to a preliminary injunction enjoining the government from enforcing the 2021 Rule’s program integrity rules in Ohio in a manner that would affect the allocation of funding in Ohio. While the doctrinal landscape undergirding Rust has shifted significantly since it was decided, Rust, and its application of Chevron, remain binding. The 2021 Rule’s referral requirement is not an impermissible interpretation of section 1008 but the program-integrity requirements do not represent a permissible interpretation. View "State of Ohio v. Becerra" on Justia Law

The Township solicited bids for the demolition of former hospital buildings. ICC, a Detroit-based minority-owned company, submitted the lowest bid. AAI, a white-owned business submitted the second-lowest bid, with a difference between the bids of almost $1 million. The Township hired a consulting company (F&V) to vet the bidders and manage the project. F&V conducted interviews with both companies and provided a checklist with comments about both companies to the Township. ICC alleges that F&V made several factual errors about both companies, including that AAI had no contracting violations and that ICC had such violations; that ICC had no relevant experience, that AAI had relevant experience, and that AAI was not on a federal contracting exclusion list. F&V recommended that AAI receive the contract. The Township awarded AAI the contract. ICC filed a complaint, alleging violations of the U.S. Constitution, federal statutes, and Michigan law.The district court dismissed the case, finding that ICC failed to state a claim under either 42 U.S.C. 1981 or 42 U.S.C. 1983 by failing to allege the racial composition of its ownership and lacked standing to assert its constitutional claims and that F&V was not a state actor. The Sixth Circuit reversed in part. ICC had standing to bring its claims, and sufficiently pleaded a section 1981 claim against F&V. The other federal claims were properly dismissed. View "Inner City Contracting LLC v. Charter Township of Northville" on Justia Law

Plaintiff employees who opted out of their union and employer-sponsored health plans received a monetary credit, part of which was deducted as a fee that was then used to fund the plans from which plaintiffs had opted out. Plaintiffs argue that this opt-out fee should be treated as part of their “regular rate” of pay for calculating overtime compensation under the Fair Labor Standards Act (FLSA).   The Ninth Circuit affirmed the district court’s grant of summary judgment. The panel held that the opt-out fees were not part of the employees’ “regular rate” of pay, but rather were exempted as “contributions irrevocably made by an employer to a trustee or third person pursuant to a bona fide plan for providing” health insurance under 29 U.S.C. Section 207(e)(4). View "ANTHONY SANDERS, ET AL V. COUNTY OF VENTURA" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court for attempted murder and other crimes with respect to Defendant's contended errors but vacated Defendant's sentences with respect to domestic violence assault and domestic violence terrorizing, holding that those sentences exceeded the maximum allowable under Me. Rev. Stat. 17-A, 1604(1)(D).On appeal, Defendant argued that the trial court abused its discretion by imposing a discovery sanction under M.R.U. Crim. P. 16(e) and that the jury venire was not drawn from a fair cross-section of the community. The Supreme Judicial Court affirmed the convictions but vacated the sentences in part, holding (1) the trial court's discovery sanction constituted a fundamentally fair balance between the parties' competing interests; (2) Defendant did not sufficiently preserve or present a sufficient record for the Supreme Court to reach Defendant's second contention; and (3) the trial court erred by entering a one-year sentence for Defendant's convictions for domestic violence assault and domestic violence, both class D misdemeanors. View "State v. Page" on Justia Law

Sergeant Albee saw a truck pulling a partially loaded car hauler semitrailer with no driver’s side markings indicating the company name or the DOT number required by federal regulations. The hauler was only partially loaded, which Albee found unusual; no registration was displayed on the trailer. During the subsequent traffic stop, Webb displayed “a state of panic” and had no organized documentation. He volunteered that he had been stopped several times and that the vehicle had been checked for drugs. Albee found that statement “bizarre.” Webb gave Albee a cab card that was Illinois apportioned, but the displayed license plate was from California. Albee performed a free air sniff test with his canine partner. After a positive alert on the trailer, a search revealed an unlicensed firearm and 2736 grams of cannabis–street value $40,000.Webb was convicted of cannabis trafficking, possession of cannabis with intent to deliver, and possession of cannabis. The appellate court and Illinois Supreme Court affirmed, rejecting Webb’s argument that his counsel was ineffective for failing to move to suppress the cannabis on the basis that the positive canine alert, without more, was not sufficient to establish probable cause following changes to Illinois cannabis legislation. Albee relied on more than the dog sniff. The totality of the facts and circumstances justified a reasonable person in believing that the vehicle contained contraband or evidence of criminal activity. View "People v. Webb" on Justia Law

Montanez was convicted based on the 2002 murder of Villalobos and Ramirez. The court sentenced him to mandatory natural life for two first-degree murder convictions, a 20-year consecutive sentence for an aggravated vehicular hijacking conviction, and a 27-year consecutive sentence for an aggravated kidnapping conviction.Montanez challenged the denial of his request for leave to file a successive postconviction petition. He sought to raise a claim that the prosecution violated “Brady” by failing to disclose evidence relevant to his defense that was stored in a file in the basement of the Chicago Police Department and was discovered after his convictions. Montanez claims that although he became aware of the file during his first postconviction proceedings (which included 46 constitutional claims) he was unable to obtain the file during those proceedings to establish that it contained material that would have been helpful to his defense.The Illinois Supreme Court affirmed the denial. In addition to failing to raise a Brady violation claim based on the entirety of the CPD file in his proposed successive petition, Montanez’s attempt to raise this claim on appeal was barred by res judicata. Montanez’s motion for leave to file a successive postconviction petition falls short of demonstrating that the procedural hurdles for filing a successive petition should be lowered in this case. View "People v. Montanez" on Justia Law

Webster, 17 years old, fatally shot 15-year-old Gutierrez with a sawed-off shotgun while in the garage behind Webster’s home. Gutierrez sustained a wound to his hand, consistent with his arm having been in a defensive position, and two shotgun wounds to his face. Webster hid the shotgun, dragged Gutierrez’s body down the alley, and tried to clean the crime scene, depositing bloodstained items in neighboring garbage receptacles. In a video-recorded interview at the police station, Webster initially said that no one had been at his house that day and he had last seen Gutierrez about a month earlier. Eventually, Webster admitted that he shot Gutierrez, claiming that Gutierrez pulled out a shotgun, pointed it at Webster, and pulled one of the hammers and that Webster grabbed the shotgun from Gutierrez, “blacked out,” and shot Gutierrez twice to “finish him off.”Webster was convicted of first-degree murder and sentenced to a term of 40 years. The appellate court vacated the sentence and remanded for a new sentencing hearing. The Illinois Supreme Court reversed, reinstating the sentence. Absent a finding of error or abuse of discretion, the appellate court is without authority under Illinois Supreme Court Rule 615(b) to vacate a defendant’s sentence and remand for resentencing. The 40-year sentence is within statutory sentencing limits and is presumed proper. View "People v. Webster" on Justia Law

In 2010, Agee strangled his girlfriend, Davis, during a physical altercation. He went directly to the police station and voluntarily made a statement, which was recorded on video. Agee did not realize that Davis had died and expressed concerns that she would be okay. Agee pled guilty to first-degree murder and was sentenced to 25 years.Agee filed a pro se post-conviction petition, alleging ineffective assistance of counsel for failing to seek an expert to testify as to his mental health. Postconviction counsel was appointed and filed an amended petition adding a claim that trial counsel was ineffective for failing to advise Agee that he could pursue a second-degree defense murder at trial. The court dismissed the amended petition. Agee appealed, arguing that postconviction counsel erroneously failed to allege all the elements of a second-degree murder claim. The appellate court affirmed, reasoning that Rule 651(c), requiring reasonable assistance of postconviction counsel, does not require “any level of representation in the presentation of new claims.”The Illinois Supreme Court affirmed. The appellate court erred in finding that Rule 651(c) does not require any level of representation in the presentation of added claims in an amended pro se postconviction petition but Agee failed to demonstrate that postconviction counsel failed to make amendments to the pro se petition as necessary for an adequate presentation of his claims. He cannot show deficient performance. The record rebuts Agee’s claims about a second-degree murder defense. View "People v. Agee" on Justia Law