Justia Civil Rights Opinion Summaries

Deari Cole was committed to a developmental center under California's Welfare and Institutions Code section 6500, which allows for the commitment of individuals with developmental disabilities who pose a danger to themselves or others. Near the end of his commitment period, a petition to extend his commitment was filed, but it was too late for a trial to occur before the original commitment expired. Cole was held pending trial and subsequently filed a petition for writ of mandate or habeas corpus, arguing that equal protection principles required his release pending trial.The Contra Costa County Superior Court initially found Cole incompetent to stand trial on charges including felony possession of a firearm and second-degree burglary. He was committed to the Porterville Developmental Center for one year. Two days before this commitment was set to expire, the People filed a petition to extend it, and the court ordered Cole held pending trial on the recommitment petition. Cole's petition for writ of mandate and/or habeas corpus was summarily denied by the Court of Appeal, but the California Supreme Court directed the appellate court to issue an order to show cause.The California Court of Appeal, First Appellate District, Division Three, reviewed the case and rejected Cole's equal protection argument. The court held that the statutory scheme under section 6500, which allows for continued confinement pending a hearing on a recommitment petition, did not violate equal protection principles. The court reasoned that the differences between individuals with developmental disabilities and those with mental health disorders justified the disparate treatment. The court concluded that the legislative distinctions were reasonable and factually based, and thus, Cole's continued confinement pending trial was constitutionally permissible. The petition was ultimately dismissed as moot. View "Cole v. Super. Ct." on Justia Law

George Loy Clarke challenged the California Department of Motor Vehicles' (DMV) decision to suspend his driver’s license following his arrest for driving under the influence (DUI). Clarke argued that the DMV's administrative hearing violated due process and that his refusal to submit to a breath or blood test should be excused. The DMV had conducted an administrative per se (APS) hearing, which led to the suspension of Clarke’s license.The Superior Court of Orange County initially denied Clarke’s petition for a writ of mandate, which sought to overturn the DMV’s decision. Clarke’s first APS hearing resulted in a suspension, but the trial court later granted his petition for a writ of mandate, remanding the case for a new hearing. At the second hearing, Clarke contested the allegations of refusal to submit to a chemical test. Despite his objections, the hearing officer (HO) admitted the DMV’s evidence and ultimately reimposed the suspension.The Court of Appeal of the State of California, Fourth Appellate District, Division Three, reviewed the case. The court found that the DMV’s practice of having a single employee act as both advocate and adjudicator during the APS hearing violated due process, as established in California DUI Lawyers Assn. v. Department of Motor Vehicles and Knudsen v. Department of Motor Vehicles. The court concluded that the HO in Clarke’s case failed to separate her roles adequately, resulting in a due process violation. This constituted structural error, necessitating a reversal of the trial court’s denial of Clarke’s petition.The Court of Appeal reversed the trial court’s order and remanded the case, directing the lower court to grant Clarke’s petition for a writ of mandate. The court also denied requests for judicial notice and to augment the record, leaving those issues to be addressed in a potential new APS hearing. View "Clarke v. Gordon" on Justia Law

Rene Galvan, a former employee of the Indiana Department of Child Services (DCS), filed a lawsuit against the State of Indiana and his former supervisor, Joanie Crum, alleging race and sex discrimination, retaliation, and a violation of his Fourteenth Amendment right to due process. Galvan, a large Mexican male, claimed he was terminated based on his race and sex and retaliated against for his complaints of discrimination. He also alleged that Crum deprived him of his property rights without due process. The district court granted summary judgment in favor of the defendants, and Galvan appealed.The United States District Court for the Southern District of Indiana granted summary judgment to the defendants, finding no evidence that Galvan’s termination was based on race or sex discrimination. The court noted that Galvan’s performance issues, including his judgment regarding child safety and professional demeanor, were well-documented. The court also found no causal connection between Galvan’s complaints of discrimination and his termination, dismissing his retaliation claim. Additionally, the court held that Galvan received adequate due process before his termination, as he was given notice of the charges and an opportunity to respond.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court agreed that Galvan failed to provide sufficient evidence to support his claims of discrimination and retaliation. The court also found that the pre-termination procedures provided to Galvan met the requirements of due process, as he was given notice of the charges and an opportunity to respond. The court concluded that the district court properly granted summary judgment in favor of the defendants. View "Galvan v. State of Indiana" on Justia Law

Keith M. Cole, a prisoner in the Texas Department of Criminal Justice (TDCJ) and a devout member of the Bahá’í faith, believes he must eat non-pork meat with every meal. TDCJ, however, only provides non-pork meat in about two-thirds of its meals. Cole sued TDCJ under the Religious Land Use and Institutionalized Persons Act (RLUIPA), claiming that the prison's meal policy violated his religious rights. TDCJ offers three meal options: a regular tray, a meat-free tray, and a pork-free tray, but none replace excluded items with non-pork meat. Cole supplemented his diet by purchasing non-pork meat from the commissary, incurring significant personal expenses.The United States District Court for the Eastern District of Texas granted summary judgment in favor of TDCJ. The court held that TDCJ had a compelling interest in controlling costs and that its meal-selection policy was the least restrictive means of furthering that interest. The magistrate judge's report, adopted by the district court, concluded that TDCJ's policy was justified despite Cole's objections.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court found that TDCJ provided no evidence to support its claim of a compelling interest in controlling costs or that its policy was the least restrictive means of achieving that interest. The court emphasized that RLUIPA requires the government to demonstrate that it has no other means of achieving its goal without imposing a substantial burden on religious exercise. The Fifth Circuit vacated the district court's summary judgment and remanded the case for further proceedings, noting that TDCJ's unsupported assertions were insufficient to meet the strict scrutiny standard required under RLUIPA. View "Cole v. Collier" on Justia Law

A psychiatrist employed at a public university's medical school participated in a panel discussion on childhood gender dysphoria, expressing views that were unpopular with his colleagues and supervisors. Following his remarks, he was demoted and his contract was not renewed after over fifteen years of employment. He sued several university officials, alleging First Amendment retaliation.The United States District Court for the Western District of Kentucky denied the defendants' motions for summary judgment, which argued for Eleventh Amendment immunity and qualified immunity. The court found material fact disputes regarding whether the defendants retaliated against the plaintiff for his protected speech.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plaintiff's speech was protected under the First Amendment as it addressed a matter of public concern and was not made pursuant to his official duties. The court also found that the plaintiff's interest in speaking on the topic outweighed the university's interest in maintaining workplace efficiency. The court determined that the adverse actions taken against the plaintiff, including his demotion and contract nonrenewal, were motivated by his protected speech.The Sixth Circuit affirmed the district court's denial of summary judgment, concluding that the defendants were not entitled to Eleventh Amendment immunity or qualified immunity. The court held that the plaintiff's rights were clearly established and that a reasonable university official would have understood that retaliating against him for his speech was unlawful. The court also denied the plaintiff's motion to dismiss the appeal for lack of jurisdiction as moot. View "Josephson v. Ganzel" on Justia Law

Corey McNellis, a former Athletic Director and Assistant Principal at Ponderosa High School in the Douglas County School District (DCSD), was placed on administrative leave and subsequently terminated after expressing reservations about a school play, "The Laramie Project," in a staff email chain. McNellis offered to add a "Christian perspective" to the production, which led to his investigation and termination.McNellis sued DCSD in the United States District Court for the District of Colorado, alleging First Amendment retaliation under 42 U.S.C. § 1983, and religious discrimination and retaliation under Title VII and Colorado law. The district court dismissed the case under Federal Rule of Civil Procedure 12(b)(6), finding that McNellis failed to state a plausible claim for relief.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the dismissal of McNellis's First Amendment retaliation claim, concluding that his speech was made pursuant to his official duties and not as a private citizen. The court also affirmed the dismissal of his retaliation claims under Title VII and CADA, finding that McNellis failed to plausibly allege a causal connection between his complaints about the investigation and his termination.However, the Tenth Circuit reversed the dismissal of McNellis's discrimination claims under Title VII and CADA. The court found that McNellis had plausibly alleged that his termination was linked to his religious comments, which could give rise to an inference of discrimination. The case was remanded for further proceedings on these claims. View "McNellis v. Douglas County School District" on Justia Law

In the early morning, Javier Ambler II was driving without dimming his high beams, prompting a Texas sheriff’s deputy to signal him to stop. Ambler refused, leading to a high-speed chase involving multiple officers. The pursuit ended when Ambler crashed into trees in Austin, Texas. As officers attempted to arrest him, Ambler, who had congestive heart failure, repeatedly stated he could not breathe. Despite his pleas, Austin City Policeman Michael Nissen and other officers continued to restrain him. Ambler was eventually handcuffed but appeared limp and was later pronounced dead at a hospital. His family sued, alleging excessive force and bystander liability.The United States District Court for the Western District of Texas denied Nissen’s motion for summary judgment on qualified immunity grounds, citing genuine disputes of material fact. The court found that the facts, viewed in the light most favorable to the plaintiffs, could support a finding that Nissen used excessive force and failed to intervene to prevent other officers from using excessive force.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that it lacked jurisdiction to review the district court’s denial of summary judgment because the appeal did not turn on a pure issue of law but rather on disputed facts. The court emphasized that factual disputes, such as whether Ambler was resisting arrest or posed a threat, were material to the plaintiffs’ claims and should be resolved by a jury. Consequently, the Fifth Circuit dismissed the appeal and remanded the case for further proceedings. View "Ambler v. Nissen" on Justia Law

In 1988, a California jury sentenced Jerry Grant Frye to death for the first-degree murders of Robert and Jane Brandt. Frye and his girlfriend, Jennifer Warsing, had moved to Amador County to grow marijuana. Warsing testified that Frye, after seeing the devil and feeling threatened, forced her to accompany him to the Brandts' cabin, where he shot and killed them. They then stole the Brandts' valuables and fled to South Dakota, where Frye was later arrested and confessed to the murders. The prosecution's case relied heavily on Warsing's testimony, corroborated by physical evidence and Frye's own statements.The California Supreme Court affirmed Frye's conviction and sentence in 1998. Frye filed a state habeas petition in 2000, claiming his due process rights were violated when jurors saw him shackled during the trial. The California Supreme Court summarily denied the petition on the merits in 2001. Frye then sought federal habeas relief, and in 2022, the district court granted a writ of habeas corpus on the shackling claim, concluding that the shackling prejudiced Frye at both the guilt and penalty phases.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's order. The Ninth Circuit held that Frye did not overcome the significant deference owed to an unreasoned state court decision on the merits under the Antiterrorism and Effective Death Penalty Act (AEDPA). The court rejected the argument that the right to be free from unjustified guilt-phase shackling was not clearly established federal law at the time of the state court's decision. However, given the limited shackling evidence and the guilt evidence before the state court, the Ninth Circuit concluded that every fairminded jurist would not agree that the state court's harmlessness decision was objectively unreasonable. The case was remanded for further proceedings on Frye's remaining claims. View "FRYE V. BROOMFIELD" on Justia Law

Rachel Ann Niemeyer was questioned by police after her husband suffered a gunshot wound to the head. During the interrogation at the police station, Niemeyer made incriminating statements. She was charged with murdering her husband and moved to suppress these statements, arguing they were obtained in violation of Miranda v. Arizona. The trial court denied her motion, concluding she was not in custody when she made the statements. A jury convicted her of second-degree murder and other offenses.The Colorado Court of Appeals affirmed the trial court's decision. The majority held that a reasonable person in Niemeyer's position would not have considered herself in custody, as her freedom of action was not curtailed to the degree associated with a formal arrest. The court reasoned that the hand-bagging procedure did not convert the situation into a custodial one. However, a dissenting judge argued that the police's actions and statements indicated that Niemeyer was in custody, as they would not consider taking her to the hospital until completing unspecified tasks.The Supreme Court of Colorado reviewed the case and held that Niemeyer was in custody for Miranda purposes during the interrogation. The court found that a reasonable person in her position would have believed they were deprived of their freedom of action to a degree associated with a formal arrest. The court noted that Niemeyer was alone in an interrogation room late at night, repeatedly asked to go to the hospital, and was physically restrained with zip-tied bags on her hands. The court concluded that the trial court's error in admitting her statements was not harmless and reversed the judgment of the court of appeals, remanding for further proceedings. View "Niemeyer v. People" on Justia Law

The defendant, Phillip Romero, was charged with multiple offenses, including assault and false imprisonment, after threatening and attacking his romantic partner. During jury selection, the prosecution used a peremptory strike to excuse Prospective Juror F, one of two Hispanic jurors in the pool. Romero raised a Batson challenge, arguing that the strike was racially motivated. The prosecution explained that the juror appeared disinterested and unfocused. The trial court denied the Batson challenge, finding the prosecution's reason credible and race-neutral.The Colorado Court of Appeals reviewed the case and reversed the trial court's decision, concluding that the trial court had clearly erred in denying the Batson challenge. The appellate court held that the prosecution's reason lacked specific factual justification and objective evidence, and thus, the trial court should not have credited it. The appellate court ordered a new trial for Romero.The Supreme Court of Colorado reviewed the appellate court's decision. The Supreme Court held that the appellate court misapplied the clear error standard of review by not deferring to the trial court's credibility determinations. The Supreme Court emphasized that the trial court is in the best position to assess demeanor and credibility. It found that the trial court had implicitly found the prosecution's reason credible and that the record supported this finding. The Supreme Court reversed the appellate court's decision and remanded the case for consideration of other issues raised by Romero on appeal. View "People v. Romero" on Justia Law