Justia Civil Rights Opinion Summaries

Enrique Aguilar was involved in a shootout with San Diego Police Department officers after leading one officer on a foot chase during which he brandished a gun. Although Aguilar was wounded, none of the officers were hit, and a bullet fired from Aguilar’s direction struck a nearby store door. Aguilar was charged with multiple offenses, including attempted voluntary manslaughter, assaulting peace officers with a semiautomatic firearm, shooting at an occupied building, possessing methamphetamine while armed, and being a felon in possession of a firearm. At trial in September 2023, a jury convicted him of all charges and the court sentenced him to a lengthy prison term.During jury selection in the Superior Court of San Diego County, the prosecutor used a peremptory challenge to strike a Latina juror (Juror 1), claiming she struggled to understand the concept of intent, as revealed by her responses to a hypothetical question. Aguilar objected, arguing that the prosecutor was improperly excluding Hispanic and Latina jurors. The trial court accepted the prosecutor’s explanation, found Juror 1’s answers equivocal and overruled Aguilar’s objection, determining that ethnicity was not a factor in the challenge.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reviewed the denial of Aguilar’s objection de novo, as required by Code of Civil Procedure section 231.7. The appellate court found no substantial evidence supporting the trial court’s finding that Juror 1 was confused about intent; her answers were clear and consistent. The court held that “juror confusion” is a presumptively invalid reason for a peremptory challenge under section 231.7, and that the prosecution failed to rebut this presumption. The judgment was reversed and the case remanded for a new trial. View "P. v. Aguilar" on Justia Law

Several individuals and organizations sought to circulate a petition to place a campaign finance ordinance on Houston’s ballot, but the city’s charter at that time required petition circulators to be both residents and registered voters of Houston. The plaintiffs did not meet these requirements. They notified the city of their intent to circulate petitions and challenge the constitutionality of the residency and voter registration requirements. The city initially did not clarify its position but later stated it would not enforce the challenged provisions. Despite this, the plaintiffs filed suit in federal court, seeking injunctive and declaratory relief, arguing that the requirements were unconstitutional under Supreme Court precedent.The United States District Court for the Southern District of Texas first granted the plaintiffs a temporary restraining order barring enforcement of the requirements. After the petition circulation period ended, the court dismissed the claims as moot following a stipulation by the parties. The plaintiffs moved to alter or amend the judgment, which was denied. On appeal, the Fifth Circuit reversed, holding that the plaintiffs had standing and that the case was not moot, and remanded for further proceedings. On remand, the district court granted the plaintiffs declaratory relief and, after the city repealed the challenged provisions, awarded the plaintiffs attorneys’ fees as prevailing parties. However, in a subsequent appeal, a different Fifth Circuit panel concluded there was no case or controversy because all parties agreed the provisions were unconstitutional, vacated the judgment, and remanded for dismissal.On remand, the district court vacated the attorneys’ fees award and ordered reimbursement to the city. The United States Court of Appeals for the Fifth Circuit affirmed this ruling, holding that after the prior appellate decision vacated the underlying merits judgment for lack of a case or controversy, there was no basis for a fee award under Rule 60(b)(5). The court also clarified that the city was not required to appeal the fee award directly, and the plaintiffs’ claims of prejudice were unavailing. View "Pool v. City of Houston" on Justia Law

After the Texas Legislature passed the Election Protection and Integrity Act of 2021 (“S.B.1”), a sweeping law that amended numerous aspects of the state’s election procedures, multiple groups of plaintiffs—including civil rights and voter advocacy organizations—challenged thirty-eight provisions of the law. They alleged violations of various constitutional amendments, the Voting Rights Act (VRA), the Americans with Disabilities Act (ADA), and the Rehabilitation Act, naming state officials including the Texas Secretary of State and Attorney General as defendants.In the United States District Court for the Western District of Texas, the defendants moved to dismiss on grounds of sovereign immunity and lack of standing. The district court addressed the motions on a provision-by-provision basis, concluding that the Secretary and Attorney General were sufficiently connected to the enforcement of most challenged provisions to overcome sovereign immunity under Ex parte Young, and that plaintiffs had standing to sue. It denied the motions to dismiss for the majority of the claims, although it dismissed others as moot, for lack of standing, or for failure to state a claim. The defendants appealed the denials.The United States Court of Appeals for the Fifth Circuit held it had appellate jurisdiction over the interlocutory sovereign immunity appeals. On the merits, the Fifth Circuit affirmed in part and reversed in part. It held that the VRA claims were not barred by sovereign immunity. For the constitutional and other statutory claims brought under 42 U.S.C. § 1983, the court determined that the Secretary of State is a proper defendant only for those provisions she directly enforces—such as those involving the design of forms and sanctioning of registrars—and not for those enforced by other officials. Similarly, it held the Attorney General could be sued only for one provision authorizing civil penalties. The court affirmed standing for claims against provisions enforced by these officials. View "Un del Pueblo Entero v. Nelson" on Justia Law

In June 2021, police officers in Aurora, Illinois responded to a 911 call from a woman who reported, based on information from her nephew, that Antron Cannon was violently assaulting a woman inside his home. Officers arrived to find Cannon and a companion inside the house. There were discrepancies between Cannon’s account and that of other witnesses regarding what occurred, but responding officers heard loud noises, received confirmation that no one had left the home, and were told a side door was unlocked. They entered the home without a warrant, detained Cannon, and interviewed his companion, who alleged that Cannon had assaulted her. Physical evidence of injuries was documented, and Cannon was arrested for domestic battery, though the charges were later dropped.The United States District Court for the Northern District of Illinois, Eastern Division, reviewed Cannon’s subsequent civil lawsuit against the officers and the city. Cannon claimed the officers unlawfully entered his home and arrested him without probable cause. The district court granted summary judgment for the defendants, concluding that exigent circumstances justified the warrantless entry and probable cause supported the arrest. The court also dismissed Cannon’s indemnification claim against the city and awarded defendants their costs, rejecting Cannon’s argument that his indigency should exempt him from the cost award.The United States Court of Appeals for the Seventh Circuit reviewed the appeal. The appellate court affirmed the district court’s decisions. It held that the officers’ warrantless entry was reasonable under the emergency aid exception to the Fourth Amendment, given the information available to them at the time. It further held that probable cause existed for Cannon’s arrest based on statements and observed injuries. Finally, it found no abuse of discretion in awarding costs, as Cannon did not demonstrate inability to pay now or in the future. View "Cannon v. Filip" on Justia Law

A former lieutenant in a county sheriff’s office was accused of using excessive force during two arrests. After an internal investigation was initiated, he was suspended and scheduled for a public hearing before a merit board, which is required under Indiana law for disciplinary actions. The lieutenant alleged that the sheriff manipulated both the investigation and the merit board to ensure an unfavorable outcome for him. Faced with the possibility of an unfair hearing and negative publicity, the lieutenant negotiated a severance agreement with the sheriff: he would resign and waive his hearing in exchange for withdrawal of the charges and a promise of a neutral reference.Despite the agreement, on the day the resignation became effective, two county prosecutors and the sheriff broadly disclosed the excessive-force allegations to local legal professionals and the lieutenant’s current and prospective employers, including through Brady/Giglio disclosures. The disclosures described the alleged misconduct and claimed issues with the lieutenant’s credibility, leading to his suspension from his part-time job and the loss of other employment opportunities. The lieutenant claimed these actions were part of a premeditated scheme to render him unemployable in law enforcement.In the United States District Court for the Northern District of Indiana, the complaint was dismissed. The district court found that absolute and qualified immunity protected the prosecutors and that the sheriff could not be liable because the lieutenant had voluntarily resigned, waiving his due process rights. On appeal, the United States Court of Appeals for the Seventh Circuit held that the prosecutors were entitled to absolute immunity only for Brady/Giglio disclosures made in pending criminal cases. For disclosures to the bar association and employers, neither absolute nor qualified immunity applied at this stage because the alleged coercion through misrepresentation could constitute a procedural due process violation. The appellate court reversed in part, affirmed in part, and remanded for further proceedings. View "Martin v. Goldsmith" on Justia Law

In September 2020, a college student alleged she was sexually assaulted by a man during a late-night traffic stop in Virginia. She reported the incident to local law enforcement and participated in multiple interviews with detectives, who investigated her claims but found surveillance footage that was low-quality and recorded at a different time than the alleged assault. During a subsequent interview, detectives pressured her about inconsistencies in the evidence and, after the interview, she received threatening text messages. The detectives later told university officials she had confessed to fabricating her report. The sheriff then directed detectives to use her confession as probable cause for an arrest warrant charging her with filing a false police report. After her arrest, officers issued a press release with her personal information and photo, which led to widespread public shaming and emotional distress.Initially, she was convicted in a bench trial in Washington County District Court, but after appealing, her conviction was annulled and she was acquitted in a de novo bench trial in Washington County Circuit Court. She then sued the officers and the sheriff in the United States District Court for the Western District of Virginia, alleging violations of her constitutional rights and state law torts.The district court dismissed the complaint under Rule 12(b)(6), relying on an audio recording of the key interview. The court found the recording contradicted her claims of coercion, ruling that it showed a civil discussion without coercion and that her confession appeared voluntary. It also found her allegation of having no choice but to confess was not credible based on the recording.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the district court erred by dismissing the complaint based on the audio recording, because the recording did not "blatantly contradict" her factual allegations as required by Fourth Circuit precedent. The appellate court vacated the dismissal and remanded the case for further proceedings. View "Bermeo v. Andis" on Justia Law

The case concerns the fatal shooting of Kwamena Ocran by four Gaithersburg Police Department officers in January 2021. Ocran, who had recently been released from prison and was reported by a confidential informant to be armed, was surveilled by the officers after the informant indicated Ocran might attempt to sell a handgun. When Ocran left an apartment with the informant and was approached by the officers, he fled. The officers pursued him, and during the chase, multiple officers reported seeing a muzzle flash and believed Ocran fired a weapon in their direction. The officers collectively discharged 27 rounds, resulting in Ocran’s death. Forensic evidence revealed Ocran was shot multiple times in the back, and a handgun was found near his body, though no evidence indicated it had been fired.After discovery, Melody Cooper, Ocran’s mother and personal representative, brought a 42 U.S.C. § 1983 claim alleging excessive force in violation of the Fourth Amendment. The United States District Court for the District of Maryland denied the officers’ motion for summary judgment and rejected their claim of qualified immunity, finding genuine disputes of material fact existed—particularly regarding whether Ocran pointed or fired his weapon at the officers. The court also denied the officers’ motion for reconsideration.On appeal, the United States Court of Appeals for the Fourth Circuit dismissed the officers’ appeal to the extent it challenged the district court’s findings of disputed material facts, as such findings are not reviewable under the collateral order doctrine. The Fourth Circuit affirmed the district court’s ruling that, accepting the undisputed facts, the officers were not entitled to qualified immunity because the right to be free from deadly force when fleeing and not posing a significant threat was clearly established at the time of the incident. The case was remanded for further proceedings, including a jury trial. View "Cooper v. Doyle" on Justia Law

A former assistant principal at a middle school in the Central Valley School District posted a Facebook comment about the Democratic National Convention that included epithets, slurs, and violent language. The post, though made on his private account and shared with Facebook friends, was seen by other school district employees and quickly forwarded to administrators. Within days, the assistant principal was placed on paid administrative leave, prohibited from contacting district staff or students, and ultimately transferred to a non-administrative teaching position. The school district’s investigation revealed additional concerns about derogatory comments he had made at work. The district offered him a voluntary transfer if he signed a release of claims, which he rejected, leading to further administrative proceedings and the final transfer decision.Previously, the United States District Court for the Eastern District of Washington reviewed the case. The court initially denied summary judgment to individual administrators on qualified immunity, a decision affirmed by the Ninth Circuit on interlocutory appeal. After further discovery and cross-motions for summary judgment, the district court granted summary judgment to the school district and the individual administrators. The court found the plaintiff had established a prima facie First Amendment retaliation claim but held that the district’s interests outweighed the plaintiff’s under the Pickering balancing test. Qualified immunity was also found to apply to the individual defendants.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s rulings. It held that while the plaintiff’s Facebook post was private speech on a matter of public concern and he made a prima facie case for retaliation, the school district showed a reasonable prediction of disruption and its interest in maintaining a safe and inclusive environment outweighed the plaintiff’s First Amendment interests. The court also affirmed qualified immunity for the individual administrators. View "Thompson v. Central Valley School District No 365" on Justia Law

On July 29, 2007, Noel Dean’s wife, Shannon, died from a gunshot wound at their home after she became severely intoxicated and after Noel confronted her with evidence of an affair. Noel reported that Shannon shot herself, but law enforcement suspected homicide. The next day, Dr. Darshan Phatak, an assistant medical examiner, performed the autopsy. Initially, he could not determine whether the death was a homicide or suicide and marked the cause as “pending.” After meeting with colleagues and reviewing police interviews and other evidence, Dr. Phatak concluded the gun’s orientation at the time of the shooting was inconsistent with Noel’s account and classified the death as a homicide in the official autopsy report. This report contributed to Noel’s arrest and indictment for murder. During a subsequent trial, photographic overlays created by Dr. Phatak’s supervisor suggested the gun orientation matched Noel’s story, prompting a change in the autopsy report’s classification to “undetermined” and a dismissal of charges.Noel Dean then filed a civil rights lawsuit under 42 U.S.C. § 1983, alleging Dr. Phatak intentionally fabricated the autopsy report. The United States District Court for the Southern District of Texas denied Dr. Phatak’s summary judgment motion based on qualified immunity, relying on allegations rather than evidence. On initial appeal, the United States Court of Appeals for the Fifth Circuit vacated and remanded for proper consideration of the summary judgment record. After further briefing and significant delay, the district court again denied summary judgment, applying a “deliberate indifference” standard.On this second interlocutory appeal, the United States Court of Appeals for the Fifth Circuit held that the district court applied the wrong legal standard by using a “deliberate indifference” test rather than determining whether a rational juror could find Dr. Phatak intentionally misstated his conclusions. The appellate court vacated the denial of summary judgment and remanded for reconsideration under the correct standard. View "Dean v. Phatak" on Justia Law

A group of unhoused veterans with severe disabilities and mental illnesses sued the United States Department of Veterans Affairs (VA) and the Department of Housing and Urban Development (HUD), seeking to restore the West Los Angeles VA Grounds for its intended use: housing disabled veterans. The VA had leased portions of this land to third parties—including the Regents of the University of California, Brentwood School, and Bridgeland Resources LLC—for uses that did not principally benefit veterans. Plaintiffs argued that the lack of supportive housing denied meaningful access to VA healthcare, violated the Rehabilitation Act, and placed them at serious risk of institutionalization. They also challenged VA policies that counted disability benefits as income, restricting access to supportive housing, and claimed that certain land-use agreements violated the Administrative Procedures Act (APA). Additionally, they asserted that the original 1888 Deed created a charitable trust that the VA had breached.The United States District Court for the Central District of California held a four-week bench trial, finding that the VA’s land-use leases with UCLA, Brentwood School, and Bridgeland Resources LLC were unlawful, voided these leases, and enjoined the VA from renegotiating them. The court certified a plaintiff class, ordered the VA to build supportive housing, found the VA and HUD violated the Rehabilitation Act in several respects, and determined that the VA had breached fiduciary duties under a charitable trust theory, invalidating certain leases on that basis as well.On review, the United States Court of Appeals for the Ninth Circuit affirmed in part, reversed in part, vacated in part, and remanded. The Ninth Circuit held that federal courts retained jurisdiction over plaintiffs’ Rehabilitation Act claims, upheld class certification, and affirmed findings of meaningful access, Olmstead, and facial discrimination under the Rehabilitation Act against the VA. The court reversed judgment against HUD, and also reversed the charitable trust claim, finding no judicially enforceable fiduciary duties under the Leasing Act. The court vacated related injunctive relief and judgments based on the charitable trust theory, including those against UCLA, Brentwood, and Bridgeland. The injunctions were modified, allowing the VA to renegotiate leases if compliant with statutory requirements. View "Powers v. McDonough" on Justia Law