Justia Civil Rights Opinion Summaries

A man was stopped by law enforcement in Marion County, West Virginia, while driving a Jeep with an inoperable brake light and a mismatched license plate. During the stop, he appeared nervous, admitted to not having a valid license, and refused consent to search the vehicle. A drug-sniffing dog alerted to the presence of narcotics. The subsequent search revealed a loaded firearm in the center console, a substantial quantity of methamphetamine and fentanyl, drug trafficking paraphernalia, and $1,863 in cash on the driver. The vehicle had recently been purchased by the man from an acquaintance, but the title was still in the seller’s name. Both the driver and his passenger were arrested.After indictment on eight counts, a jury in the Circuit Court of Marion County found the man guilty of six felony offenses, including conspiracy and possession with intent to deliver controlled substances, and possession of a firearm by a prohibited person. The jury acquitted him of one firearm-related offense and one drug charge was dismissed. Following the convictions, the State filed a recidivist information based on two prior felony convictions—strangulation and fleeing in a vehicle with reckless indifference. At a recidivist trial, the jury found the defendant had committed the prior felonies. The circuit court imposed several concurrent sentences on the substantive offenses and a life sentence with parole eligibility, pursuant to the recidivist statute, for possession of a firearm by a prohibited person.On appeal to the Supreme Court of Appeals of West Virginia, the defendant challenged the sufficiency of the evidence and the constitutionality of his life recidivist sentence. The court held that the evidence, when viewed most favorably to the prosecution, was sufficient for a rational jury to convict on all counts. Additionally, the court found that the triggering and predicate felonies met the statutory and constitutional requirements for a life recidivist sentence. The sentencing order was affirmed. View "State v. Valentine" on Justia Law

Jonathan López-Díaz pleaded guilty in 2014 to bank robbery and illegal possession of a firearm, serving ninety-three months in prison. After release, he began supervised release but repeatedly violated its conditions, including multiple positive drug tests for cocaine and marijuana and admitted drug use. The United States Probation Office reported additional violations, such as failing to follow instructions, not reporting law enforcement contacts, and missing treatment appointments. After these repeated violations, the district court revoked his supervised release twice, ultimately sentencing him to twelve months’ imprisonment with no further supervised release following his second revocation.The United States District Court for the District of Puerto Rico originally handled López’s supervised release and revocation proceedings. After López’s second revocation, his counsel argued at the revocation hearing that his violations should be classified as Grade C rather than Grade B under the Sentencing Guidelines, which would result in a lower advisory sentencing range. Counsel also argued for leniency and additional supervision with rehabilitative conditions rather than incarceration. The government contended that López’s conduct constituted a Grade B violation, given his admissions and repeated positive drug tests, and requested imprisonment without further supervised release.The United States Court of Appeals for the First Circuit reviewed López’s appeal. Applying abuse-of-discretion review, the court held that the district court correctly classified López’s violation as a Grade B violation based on his admissions and corroborating evidence. The First Circuit further found the district court’s sentencing rationale did not improperly rely on retributive factors barred by Esteras v. United States, and that the imposed sentence was both procedurally and substantively reasonable. The court affirmed López’s twelve-month sentence with no term of supervision to follow. View "US v. Lopez-Diaz" on Justia Law

Several individuals required to register as sex offenders under Michigan’s Sex Offenders Registration Act (“SORA 2021”) challenged the statute’s constitutionality after its 2021 amendment. Most plaintiffs had committed their offenses before 2011 and had their registration terms retroactively extended, often to lifetime registration, without individualized risk assessments. SORA 2021 retained offense-based tier assignments and many reporting and public notification requirements, although it removed some prior features such as student safety zones and tier designations from public display.The U.S. District Court for the Eastern District of Michigan certified a class and subclasses, and addressed several constitutional challenges. The district court granted summary judgment to the plaintiffs on their ex post facto claims regarding retroactive application, and on procedural due process claims for individuals with non-Michigan convictions, finding that Michigan State Police’s process lacked sufficient procedural protections. It rejected plaintiffs’ substantive due process and equal protection challenges to offense-based tiers and their equal protection challenge to petitioning restrictions, concluding SORA 2021 was rationally related to recidivism reduction. The court also rejected void-for-vagueness claims concerning certain reporting requirements.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s judgment de novo. The court vacated and remanded the ex post facto claims and retroactive plea agreement claim for the district court to determine whether they were mooted by a recent Michigan Supreme Court decision holding SORA 2021’s retroactive application unconstitutional. The Sixth Circuit affirmed the district court’s rejection of substantive due process and equal protection challenges to offense-based tiers and petitioning restrictions, holding these provisions were rationally related to legitimate state interests. It also affirmed the district court’s finding that Michigan’s process for registering individuals with non-Michigan convictions violated procedural due process rights, and upheld the dismissal of void-for-vagueness claims regarding education, employment, and vehicle reporting. The judgment was affirmed in part, vacated in part, and remanded for further proceedings. View "Doe v. Whitmer" on Justia Law

A prisoner serving life imprisonment following a death sentence challenged the conditions of his long-term solitary confinement in a high-security Connecticut facility. After the death penalty was abolished in Connecticut, the inmate’s sentence was changed to life without parole, but he remained in solitary confinement under conditions mandated by a state statute (section 18-10b). He argued that these conditions violated his rights under the Eighth Amendment and the Due Process Clause of the Fourteenth Amendment.Previously, the United States District Court for the District of Connecticut denied the prison officials’ motion for judgment as a matter of law based on qualified immunity and granted the prisoner’s motion for a new trial. The District Court had also divided the due process claim into two periods: before and after 2017, and a jury found the officials liable only for the period after 2017. The court ordered a new trial on the Eighth Amendment claim, ruling that the jury’s verdict was against the weight of the evidence, and denied judgment as a matter of law for the officials on both the Eighth Amendment and due process claims.The United States Court of Appeals for the Second Circuit reviewed the case. It determined it lacked jurisdiction to review the denial of qualified immunity for the Eighth Amendment claim, as unresolved factual disputes remained. However, the court found it had jurisdiction over the denial of qualified immunity on the post-2017 due process claim because the relevant facts were undisputed. The court held that the prison officials did not violate clearly established law regarding the due process claim and were therefore entitled to qualified immunity for that period. The appeal was dismissed in part, the district court’s order was reversed in part, and the case was remanded for further proceedings. View "Reynolds v. Quiros" on Justia Law

Ronald L. Green, a revenue agent employed by the Internal Revenue Service in Las Vegas, was indefinitely suspended in August 2006 on suspicion of filing fraudulent tax returns. Shortly before the suspension took effect, he applied for immediate disability retirement, citing medical conditions and workplace stress. After his suspension, he initiated arbitration to challenge the agency’s action and alleged discrimination through an EEO complaint. The Office of Personnel Management approved his retirement in January 2007. In March 2007, an arbitrator reversed his suspension but denied his discrimination claims. The agency retroactively dated his retirement to his last day of pay and removed references to other adverse actions from his record.Mr. Green’s subsequent legal efforts included appeals to the Equal Employment Opportunity Commission and district court, both of which ruled against him, with the Ninth Circuit affirming. In May 2023, he appealed to the Merit Systems Protection Board, asserting that his 2006 retirement was involuntary due to agency actions and discrimination. The administrative judge dismissed the appeal for lack of jurisdiction, finding that Mr. Green failed to nonfrivolously allege involuntariness. The decision became the Board’s final determination.The United States Court of Appeals for the Federal Circuit reviewed Mr. Green’s petition. It first determined jurisdiction, concluding that Mr. Green’s explicit waiver of discrimination claims allowed the court to review the non-discrimination aspects. The court found that Mr. Green had forfeited arguments about agency failure to restore his employment after arbitration because these were not properly raised before the Board. On the remaining issue, the court held that Mr. Green failed to nonfrivolously allege that his retirement was involuntary, either through coercion or misinformation, and affirmed the Board’s decision. View "Green v. Merit Systems Protection Board" on Justia Law

Kelly was suspected of illegal drug activity after Detective Jonathan Smith observed a drug sale involving a black male who left the scene in a red vehicle with a white female passenger. Shortly after, Deputy Cody Jett received an anonymous tip indicating Heather McDonald would arrive in a red Hyundai at a McDonald’s restaurant, accompanied by a black male driver, and that both individuals possessed heroin and were dealing drugs. Deputy Jett verified an arrest warrant for McDonald. At the restaurant, Jett observed a vehicle matching the tip, McDonald, and a black male later identified as Kelly. After Kelly and McDonald responded to Jett’s instructions, McDonald attempted to flee and was apprehended, while Kelly was detained and eventually admitted there were drugs in the vehicle. Officers subsequently obtained a search warrant, found additional evidence, and arrested Kelly for driving with a suspended license and several drug offenses.The United States District Court for the Middle District of Florida initially denied the officers’ motion to dismiss under Heck v. Humphrey, finding it could not conclude at that stage that Kelly’s Fourth Amendment claims were barred. Later, upon motions for summary judgment, the district court granted summary judgment in favor of the officers, holding that Heck barred Kelly’s suit because success would imply the invalidity of his convictions. The district court did not address qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and declined to base its decision on Heck. Instead, the appellate court found that both Deputy Jett and Detective Smith were entitled to qualified immunity because there was probable cause to detain Kelly, given the corroborated anonymous tip and observed circumstances. The Eleventh Circuit affirmed the summary judgment in favor of the officers. View "Kelly v. Jett" on Justia Law

A Sedona resident, who has obsessive-compulsive disorder, often sleeps in her car because her disability prevents her from entering her apartment. The City of Sedona has a criminal ordinance prohibiting sleeping in a vehicle on public or private property. The resident was twice warned by police for sleeping in her car and requested reasonable accommodation under the Americans with Disabilities Act (ADA) to exempt her from enforcement of this ordinance. The city denied her requests, and her landlord threatened not to renew her lease if she continued sleeping in her car. She alleges that the city’s actions caused her emotional distress and loss of income, and she continues to sleep in her car several times a week.The United States District Court for the District of Arizona dismissed her claims for lack of standing, finding that the prior police warnings were insufficient to support a specific threat of prosecution and that she failed to allege a history of enforcement against similarly situated individuals. The district court addressed only her standing to seek injunctive relief, despite her claims for damages as well. Her requests to amend her complaint were denied, and she appealed.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part the district court’s dismissal. The Ninth Circuit held that she had Article III standing to bring an ADA claim for both damages and injunctive relief, based on the city’s denial of her request for accommodation and a credible threat of future enforcement. The court further held that Title II of the ADA applies to requests for reasonable accommodation to comply with municipal criminal ordinances. The ADA claim was remanded for further proceedings, allowing her to amend her complaint, while the dismissal of her Eighth Amendment claim was affirmed. View "BERAM V. CITY OF SEDONA" on Justia Law

Stefanie Boone, a parent with children enrolled in Lowell Area Schools, publicly criticized the district’s curriculum and practices, particularly those she saw as promoting diversity, equity, inclusion, and social justice issues. She shared her views on a Facebook page, often referencing specific district employees. In response to one post, the high school principal sent Boone a letter requesting that she stop referencing district employees on social media and warning her that failure to comply could result in legal action. The letter also directed her not to contact staff without prior permission. Boone felt threatened and stopped making public comments or contacting teachers directly.Boone filed suit in the United States District Court for the Western District of Michigan, naming the district and several officials in their official capacities. She alleged violations of her First and Fourteenth Amendment rights under 42 U.S.C. § 1983, a Title IX violation, and state law claims. The district court granted the defendants’ motion to dismiss, concluding that neither the “Social Media Policy” nor the “Communication Policy” constituted unconstitutional restraints on speech—characterizing the request as non-binding and the communication restriction as merely channeling her speech. The court also rejected her Fourteenth Amendment and Title IX claims and declined to exercise supplemental jurisdiction over her state law claims.Reviewing the case de novo, the United States Court of Appeals for the Sixth Circuit held that Boone plausibly alleged a First Amendment violation regarding the Social Media Policy, as the district’s letter amounted to a coercive threat of legal action capable of chilling protected speech. However, the Communication Policy, which required Boone to channel communications through administrators, did not violate her speech rights. The court affirmed the dismissal of her Fourteenth Amendment and Title IX claims, reversed the dismissal of her First Amendment claim as to the Social Media Policy, and remanded for further proceedings, including consideration of her state law claims. View "Boone v. Lowell Area Schools" on Justia Law

Five individuals, who were either peaceful protesters or independent journalists, attended demonstrations at the U.S. Immigration and Customs Enforcement facility in Portland, Oregon. During these events, they were exposed to tear gas and pepper balls used by federal agents to disperse crowds. The protests involved both peaceful activities and significant unrest, including vandalism, blocking entrances, and attacks on law enforcement. The plaintiffs claimed that federal agents specifically targeted them in retaliation for exercising their First Amendment rights.The plaintiffs filed suit in the United States District Court for the District of Oregon against federal officials and the Department of Homeland Security. After discovery and an evidentiary hearing, the District Court issued a preliminary injunction restricting the use of non-lethal munitions to situations involving an imminent threat of physical harm, prohibiting their use on certain parts of the body, imposing limits on pepper spray, and requiring redesign of agent uniforms for better identification. Additionally, the District Court provisionally certified a class of all individuals who had protested or reported on DHS activities at the Portland ICE facility. The government’s motion to stay the injunction pending appeal was denied by the District Court but granted by the Ninth Circuit.On appeal, the United States Court of Appeals for the Ninth Circuit vacated both the preliminary injunction and the provisional class certification. The court held that the plaintiffs were not likely to succeed on the merits of their First Amendment retaliation claim, as law enforcement may use non-lethal force to clear crowds and restore order without facing an imminent threat of physical harm. The record did not support claims of an unwritten policy or intent to retaliate against First Amendment activity. The court also found the injunction overbroad and unworkable, and the class failed to meet Rule 23’s commonality and indivisible remedy requirements. The preliminary injunction and class certification were vacated. View "DICKINSON V. TRUMP" on Justia Law

Several tenants of an apartment complex located across the street from a federal Immigration and Customs Enforcement (ICE) facility in Portland, Oregon, claimed harm from exposure to tear gas used by federal law enforcement officers to disperse disruptive crowds during demonstrations. The plaintiffs, including individuals and entities associated with the apartment complex, argued that the government’s deployment of tear gas infringed their substantive-due-process rights under the Fifth Amendment.The United States District Court for the District of Oregon granted a preliminary injunction, enjoining several federal agencies from using tear gas for crowd control outside the ICE facility. The district court found that the plaintiffs were likely to succeed on the merits of their substantive-due-process claim and determined that the government’s actions could violate a constitutional right to bodily integrity.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s preliminary injunction. Applying de novo review to the underlying legal issues, the Ninth Circuit reaffirmed its prior stay of the injunction and concluded that the plaintiffs lacked a substantive-due-process right to be free from incidental exposure to tear gas used for non-lethal crowd control. The court held that such a right is not deeply rooted in the nation’s history and tradition nor implicit in the concept of ordered liberty, as required by Supreme Court precedents, including Washington v. Glucksberg and Dobbs v. Jackson Women’s Health Organization. The panel further clarified that a substantive-due-process challenge to executive action requires both conscience-shocking conduct and deprivation of a historically rooted right, rejecting the plaintiffs’ argument that only the shocks-the-conscience standard should apply. Accordingly, the Ninth Circuit vacated the district court’s preliminary injunction. View "REACH COMMUNITY DEVELOPMENT V. UNITED STATES DEPARTMENT OF HOMELAND SECURITY" on Justia Law