Justia Civil Rights Opinion Summaries

Eric Poemoceah, an Oklahoma resident and member of the Comanche Nation, participated in a protest against the Dakota Access Pipeline at the Standing Rock Reservation in North Dakota. On February 22, 2017, while attempting to negotiate with law enforcement officers for the peaceful exit of elders from the protest site, Poemoceah was tackled and arrested by officers, including Benjamin Swenson. He sustained injuries, including a pelvic fracture, and was charged with obstruction of a government function, a charge that was later dismissed.The United States District Court for the District of North Dakota dismissed Poemoceah’s complaint with prejudice, granting the defendants' motions to dismiss. The court found that the defendants were entitled to qualified immunity on the First and Fourth Amendment claims and dismissed the remaining claims as inadequately pled. Poemoceah’s request for leave to amend his complaint was also denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Poemoceah plausibly alleged a Fourth Amendment excessive force claim against Swenson, as the facts suggested that Swenson's use of force was not objectively reasonable. However, the court affirmed the dismissal of Poemoceah’s deliberate indifference to medical needs claim, First Amendment retaliation claim, supervisory liability claims, Monell claim against Morton County, and the intentional infliction of emotional distress claim under North Dakota law. The court also found no abuse of discretion in the district court’s denial of Poemoceah’s motion to amend his complaint. The case was affirmed in part, reversed in part, and remanded for further proceedings on the Fourth Amendment claim against Swenson. View "Poemoceah v. Morton County" on Justia Law

In 2009, the applicant was convicted of possessing more than one but less than four grams of cocaine and sentenced to two years and nine months in prison following a guilty plea. The conviction involved former Houston Police Department Officer Gerald Goines, who has been found to have provided false information and testimony in other drug cases. In 2019, the Harris County District Attorney’s Office informed the applicant that Goines was under criminal investigation. The applicant then filed for a writ of habeas corpus, initially on four grounds, but later amended it to focus solely on the claim that his guilty plea was involuntary due to not knowing about Goines’s misconduct.The 184th District Court of Harris County recommended granting relief, finding that the applicant’s guilty plea was involuntary and that the conviction was obtained through the use of false evidence. The court concluded that the applicant had established an inference of falsity under the Coty-Mathews framework, which applies to cases involving police officers with a history of falsifying evidence. The court found that the false evidence was material to the applicant’s guilty plea.The Court of Criminal Appeals of Texas reviewed the case to determine whether Goines’s conduct warranted an inference of falsity. The court concluded that the record did not support the habeas court’s conclusion because Goines was not the sole officer involved in the applicant’s arrest, and the evidence did not establish that Goines was the first to find the contraband. Therefore, the court held that an inference of falsity did not apply and remanded the case to the habeas court to consider the applicant’s involuntary plea claim without applying an inference of falsity. View "EX PARTE CHRISTIAN" on Justia Law

In November 2006, Lloyd Kvelstad was murdered at a house party in Havre, Montana. Evidence showed that James Main was involved in a physical altercation with Kvelstad, during which Main choked Kvelstad multiple times. Kvelstad was later found severely beaten and unresponsive. Main was arrested and charged with deliberate homicide by felony murder. At trial, various testimonies and forensic evidence linked Main to the crime, leading to his conviction in February 2009.Main appealed his conviction, but the Montana Supreme Court upheld it in 2011, finding sufficient evidence to support the jury's verdict. Main later filed a petition for postconviction relief, alleging that the State violated his Brady rights by failing to disclose certain crime scene photos. He argued that these photos were crucial for determining the time and cause of Kvelstad's death. The District Court denied Main's petition without holding a hearing, taking judicial notice of findings from a co-defendant's postconviction case.The Montana Supreme Court reviewed the case and affirmed the District Court's decision. The Court found that even if the missing photos had been disclosed, they would not have changed the outcome of the trial. The evidence already presented was sufficient to establish Main's guilt for deliberate homicide by felony murder. The Court also found that Main's petition did not present newly discovered evidence but rather a new theory of the crime. Therefore, the District Court did not abuse its discretion in denying the petition without a hearing. View "Main v. State" on Justia Law

Marc and Augustus Degenhardt alleged that Corpus Christi Police Lieutenant Phillip Bintliff unlawfully initiated a traffic stop and that Bintliff and Officer Armando Cisneros unlawfully searched and towed their vehicle, retaliating against them for engaging in protected speech. The incident occurred when Marc, driving a Dodge Challenger with Augustus as a passenger, was stopped by Bintliff, who accused Marc of reckless driving and racing another vehicle. During the stop, Cisneros arrived and observed an open box of White Claw Hard Seltzers in the car. The officers ordered the brothers out of the car, conducted a search, and impounded the vehicle, charging them with minor alcohol possession and issuing a reckless driving warning. The charges were later dropped.The United States District Court for the Southern District of Texas dismissed the suit, finding that the officers had probable cause to search the vehicle and that the officers were entitled to qualified immunity for the remaining claims. The Degenhardts appealed the dismissal.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the Degenhardts had sufficiently alleged a Fourth Amendment violation regarding the initial traffic stop, as the complaint suggested that Bintliff lacked reasonable suspicion. However, the court agreed with the district court that the officers had probable cause to search the vehicle due to the visible alcohol. The court also found that the officers were entitled to qualified immunity for the claims related to the vehicle's impoundment and the alleged retaliation for protected speech.The Fifth Circuit affirmed the district court's dismissal in part, reversed in part, and remanded the case for further proceedings regarding the Fourth Amendment claim related to the traffic stop. View "Degenhardt v. Bintliff" on Justia Law

A student at Rosalind Franklin University was accused of sexual assault by another student after a night of heavy drinking and marijuana use. The accused student, Nicholas Gash, had no memory of the events due to his intoxication. The university conducted an investigation, during which Gash received notices of allegations and participated in interviews. Despite attempting to withdraw from the university, Gash was informed that his withdrawal was not approved, and the Title IX hearing proceeded. The hearing panel found Gash responsible for the alleged assault and sanctioned him with expulsion.The United States District Court for the Northern District of Illinois dismissed Gash’s claims of sex-based discrimination under Title IX and breach of contract under Illinois law. The court found that the procedural errors cited by Gash did not suggest sex-based discrimination. Gash’s state law contract claims were also dismissed, as the court determined that he did not meet the high burden of showing that the university acted arbitrarily or in bad faith.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court’s dismissal, holding that the procedural errors and alleged biases did not plausibly suggest sex-based discrimination. The court noted that the errors could indicate a pro-victim or pro-complainant bias but not an anti-male bias. Additionally, the court found that Gash did not provide sufficient evidence to support his breach of contract claim, as he failed to show that the university acted without a rational basis or in bad faith. The court concluded that the university’s actions, while flawed, did not constitute sex-based discrimination or breach of contract. View "Gash v. Rosalind Franklin University" on Justia Law

A coalition of organizations and individuals, led by the Chinese American Citizens Alliance of Greater New York, filed a lawsuit against New York City's Mayor and Department of Education Chancellor. They challenged the revised admissions policy for the Discovery Program in the Specialized High Schools (SHSs), alleging it was intended to discriminate against Asian-American applicants by reducing their admission rates. The plaintiffs argued that the new policy, which included an Economic Need Index (ENI) criterion, negatively impacted Asian-American students.The United States District Court for the Southern District of New York granted summary judgment in favor of the City. The court concluded that the plaintiffs failed to demonstrate an aggregate disparate impact on Asian-American students, as required under Village of Arlington Heights v. Metropolitan Housing Development Corp. The court held that without showing a group-wide effect, the plaintiffs could not establish the necessary discriminatory effect for an equal protection claim.The United States Court of Appeals for the Second Circuit reviewed the case. The court assumed, for the purpose of the appeal, that the plaintiffs could prove the policy changes were made with discriminatory intent. The court concluded that the district court erred in requiring an aggregate disparate impact to establish discriminatory effect. Instead, the court held that if discriminatory intent is proven, a negative effect on individual Asian-American students would suffice to trigger strict scrutiny review. The court found that the exclusion of economically disadvantaged Asian-American students from certain middle schools due to the new ENI criterion constituted a sufficient discriminatory effect. Consequently, the Second Circuit vacated the district court's grant of summary judgment and remanded the case for further proceedings. View "Chinese Am. Citizens All. of Greater N.Y. v. Adams" on Justia Law

Joseph Segrain, an inmate at Rhode Island's Adult Correctional Institutions, filed a civil lawsuit against the Rhode Island Department of Corrections and several correctional officers, alleging violations of his Eighth Amendment rights and various state laws. Segrain claimed that on June 28, 2018, officers used excessive force by executing a leg-sweep maneuver, spraying him with pepper spray, and delaying his decontamination. The district court granted summary judgment in favor of the officers on all claims, leading Segrain to appeal.The United States District Court for the District of Rhode Island initially reviewed the case. The court found that no reasonable jury could conclude that the officers' conduct constituted an Eighth Amendment violation. It granted summary judgment on the basis that the force used was minimal and necessary to maintain order. The court also dismissed the state law claims, concluding that the officers' actions did not meet the legal standards for battery, intentional infliction of emotional distress, or excessive force under Rhode Island law.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the district court's judgment regarding the 42 U.S.C. § 1983 claim that Officer Walter Duffy's use of pepper spray violated Segrain's Eighth Amendment rights. It found that a reasonable jury could conclude that Duffy's use of pepper spray was excessive and not in good faith. The court vacated the district court's judgment on the Rhode Island Constitution Article I, Section 8 claim regarding Duffy's use of pepper spray and remanded for further proceedings. However, the court affirmed the district court's judgment on all other claims, including the leg-sweep maneuver and the delayed decontamination, granting qualified immunity to the officers on those issues. View "Segrain v. Duffy" on Justia Law

In this case, the petitioner, a state prisoner, challenged the dismissal of his federal habeas petition, which alleged violations of his constitutional rights under the Fifth, Sixth, and Fourteenth Amendments. The petitioner, along with two accomplices, planned and executed a robbery that resulted in the murder of a pizza delivery driver. The petitioner was convicted of first-degree murder, armed robbery, and breaking and entering, and was sentenced to life in prison without parole.The Massachusetts Supreme Judicial Court (SJC) affirmed the petitioner's conviction, rejecting his claims of insufficient evidence, improper admission of redacted statements from a co-defendant, and errors in jury instructions. The SJC found that the evidence was sufficient to support the petitioner's conviction under theories of felony-murder and extreme atrocity or cruelty. It also held that the redacted statements did not violate the petitioner's Confrontation Clause rights and that the trial court's jury instructions were appropriate.The United States Court of Appeals for the First Circuit reviewed the district court's denial of the habeas petition de novo. The court applied the standards set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA), which requires deference to state court decisions unless they are contrary to or involve an unreasonable application of clearly established federal law, or are based on an unreasonable determination of the facts.The First Circuit affirmed the district court's decision, holding that the SJC's rulings were not unreasonable. The court found that the evidence was sufficient to support the petitioner's conviction, the redacted statements did not violate the Confrontation Clause, and the jury instructions were proper. The court also concluded that any errors in the trial court's rulings were harmless and did not prejudice the petitioner. View "St. Jean v. Marchilli" on Justia Law

Seven plaintiffs, all members of the Air Force, challenged the Air Force’s COVID-19 vaccine mandate, arguing it violated their religious beliefs. They sought religious exemptions, which were denied, leading to administrative discharge proceedings. One plaintiff, Byron O. Starks, Jr., was separated from service, allegedly for a preexisting medical condition, though he claimed it was due to his refusal to get vaccinated.The United States District Court for the Western District of Louisiana dismissed the case as moot after the Air Force rescinded the vaccine mandate. The court also dismissed Starks’s claims for lack of standing, citing his separation from service and failure to exhaust administrative remedies.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the rescission of the mandate did not address all alleged harms, particularly the claim that the Air Force’s religious exemption process was a sham. The court held that Starks had standing because his separation caused ongoing harm, such as ineligibility for certain veteran benefits. The court also clarified that RFRA claims are not subject to the Mindes exhaustion requirement, allowing Starks to proceed without exhausting intraservice remedies.The Fifth Circuit determined that the claims of the six still-serving plaintiffs were not moot, as they alleged ongoing harm from the Air Force’s religious exemption process. The court reversed the district court’s dismissal and remanded the case for further proceedings, allowing the plaintiffs to continue their challenge against the Air Force’s broader vaccination policies and religious accommodations process. View "Crocker v. Austin" on Justia Law

A senior trooper with the Louisiana State Police (LSP), August McKay, committed suicide at his home after learning he was being reassigned and that a search warrant was to be executed on his residence. His widow, Brandy McKay, sued several LSP officers under 42 U.S.C. § 1983 and Louisiana state law, alleging their actions contributed to his death. The district court denied qualified immunity to two officers, Sergeant Rohn Bordelon and Trooper David LaCroix, leading to this appeal.The United States District Court for the Eastern District of Louisiana initially dismissed Brandy’s Eighth Amendment claim but allowed her to amend her complaint. She then limited her claims to the Fourteenth Amendment and state laws. The district court found that Brandy had sufficiently stated § 1983 claims against Sgt. Bordelon and Trooper LaCroix, concluding they had subjective knowledge of August’s suicide risk and responded with deliberate indifference. The court dismissed the claims against other defendants and allowed the state law claims against Sgt. Bordelon and Trooper LaCroix to proceed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the officers were entitled to qualified immunity because there was no constitutional duty to protect August from self-harm, as he was not in state custody or otherwise restrained. The court emphasized that the officers did not attempt to arrest or confine August, and Brandy’s complaint focused on their failure to restrain him. Without a constitutional duty, there could be no violation, and thus, the officers were entitled to qualified immunity. The court reversed the district court’s decision regarding qualified immunity and dismissed the appeal concerning the state law claims without prejudice, remanding the case for further proceedings. View "McKay v. LaCroix" on Justia Law