Justia Civil Rights Opinion Summaries

In 1997, the defendant was convicted of second-degree murder with a firearm enhancement and sentenced to 15 years to life, plus an additional 10 years. In January 2020, he filed a petition under former section 1170.95, which was summarily denied. In January 2023, he filed a motion for relief under section 745 of the California Racial Justice Act (RJA), claiming racial bias in his conviction and sentence. The trial court denied the motion, citing improper service and failure to state a violation of the RJA.The defendant appealed, arguing that he made a prima facie case for a hearing under section 745 and that the denial violated his equal protection rights. The People contended that the trial court lacked jurisdiction to consider the motion and that the denial was not erroneous. The defendant countered that his motion was authorized under section 745, subdivision (b).The California Court of Appeal, Fifth Appellate District, reviewed the case and concluded that the defendant's motion was prematurely filed under the RJA’s phased-in retroactivity provisions. Specifically, the court noted that the defendant's case fell within the last phase of eligibility for relief, commencing January 1, 2026. As a result, the trial court lacked fundamental jurisdiction to consider the motion, rendering its order void. The appellate court vacated the trial court's order and dismissed the appeal. View "People v. Vigil" on Justia Law

David Gaddie was charged with four counts of gross sexual imposition for allegedly sexually abusing a child. In a separate case, he was charged with three counts of gross sexual imposition for allegedly abusing the child's mother, but those charges were dismissed. The case involving the child proceeded to trial, and Gaddie was found guilty on all counts. On direct appeal, one conviction was reversed due to an issue with jury instructions.Gaddie then filed an application for postconviction relief, claiming ineffective assistance of counsel and prosecutorial misconduct. The State moved for partial summary dismissal, arguing that Gaddie should have raised the prosecutorial misconduct claim on direct appeal. The district court reserved ruling on this motion and held a hearing. During the hearing, it was revealed that the State had introduced a video containing statements about Gaddie abusing the child's mother, which Gaddie’s attorney had objected to during the trial. The district court denied the State's motion for partial summary dismissal but ultimately denied Gaddie’s application for postconviction relief, reasoning that the situation was a misunderstanding rather than intentional misconduct.The North Dakota Supreme Court reviewed the case and found that prosecutorial misconduct had occurred because the State introduced inadmissible prior bad act evidence without providing the required notice under N.D.R.Ev. 404(b). The Court held that this misconduct prejudiced Gaddie’s right to a fair trial. Consequently, the Supreme Court reversed the district court's judgment denying postconviction relief and remanded the case with instructions to vacate the criminal judgment and enter any supplementary orders required by law. View "Gaddie v. State" on Justia Law

The case involves a challenge to the Hawai‘i Court Records Rules, which mandate that all medical and health records filed in any court proceeding be filed under seal without further judicial order. The plaintiff, Civil Beat Law Center for the Public Interest, argued that this rule is unconstitutionally overbroad under the First Amendment, which grants the public a presumptive right to access court records.The United States District Court for the District of Hawai‘i granted summary judgment in favor of the defendants, the Chief Court Administrators of the Hawai‘i state courts. The district court held that the public does not have a presumptive First Amendment right to access medical and health records, and even if such a right existed, requiring case-by-case litigation to unseal these records did not violate the First Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s judgment. The Ninth Circuit held that the First Amendment grants the public a presumptive right to access a substantial portion of the records sealed under Hawai‘i’s mandatory sealing provision. The court found that the state’s interest in protecting individual privacy rights does not justify the categorical sealing of all medical and health records without any case-by-case consideration. The court concluded that the mandatory sealing rule is not the least restrictive means of protecting privacy interests and that case-by-case judicial review would better balance privacy concerns with the public’s right to access.The Ninth Circuit held that the Hawai‘i Court Records Rules are unconstitutionally overbroad because they encroach on the public’s right of access to court records. The court reversed the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "CIVIL BEAT LAW CENTER FOR THE PUBLIC INTEREST, INC V. MAILE" on Justia Law

Curtis Terrell, after consuming a significant amount of alcohol, pain pills, and methamphetamine, began running erratically in a residential neighborhood. His wife, Angela Terrell, called 911, requesting an ambulance. Officer Jason Allgrunn arrived and arrested Mr. Terrell. When Mrs. Terrell began filming the incident, she was also arrested. The Terrells filed multiple federal and state claims against Allgrunn and other officers involved.The United States District Court for the Western District of Louisiana denied summary judgment to the defendants on all claims, rejecting their qualified immunity defense. The defendants appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the district court's denial of summary judgment for the defendants on the Terrells' false arrest claims, finding that Officer Allgrunn had probable cause to arrest both Mr. and Mrs. Terrell. The court also reversed the denial of summary judgment on Mrs. Terrell's excessive force claim, concluding that there was no clearly established law prohibiting the officer's conduct. However, the court dismissed the appeal regarding Mr. Terrell's excessive force claim for lack of jurisdiction, as there were genuine disputes of material fact about what occurred when Mr. Terrell was out of the video frame.Additionally, the court reversed the denial of summary judgment on the Terrells' malicious prosecution and First Amendment retaliation claims, citing the presence of probable cause. The court also reversed the denial of summary judgment for Officers Henderson and Banta on the failure-to-intervene claims, as there were no violations of clearly established constitutional law.Finally, the court vacated the district court's denial of summary judgment on the Louisiana state law claims and remanded for reconsideration in light of the appellate court's opinion. View "Terrell v. Allgrunn" on Justia Law

Jermaine Randy Howard was convicted of second-degree murder after shooting a man at an unlicensed nightclub in San Jose. Howard claimed he acted in self-defense, but the jury rejected this defense. Before sentencing, Howard filed a motion alleging the prosecutor violated the California Racial Justice Act (RJA) by questioning him about his connection to East Palo Alto, which he argued was racially biased. The trial court denied the motion, finding Howard failed to make a prima facie showing of an RJA violation, and sentenced him to 19 years to life in prison.Howard appealed, arguing the trial court erred in denying his RJA motion and that the prosecutor's cross-examination and closing arguments violated the RJA and his due process rights. He also contended that the jury instructions misstated the law regarding murder, imperfect self-defense, and heat of passion, cumulatively prejudicing his defense.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court found that the trial court erred in concluding Howard had not made a prima facie showing of an RJA violation regarding the prosecutor's cross-examination about East Palo Alto. The appellate court conditionally reversed the judgment and remanded the case for further proceedings on Howard's RJA motion. The court rejected Howard's claims of instructional error, finding the jury instructions correctly stated the law and did not mislead the jury about the prosecution's burden of proof.The appellate court's main holding was that Howard made a prima facie showing of an RJA violation, warranting a hearing on his motion. The court conditionally reversed the judgment and remanded for further proceedings, affirming the conviction and sentence otherwise. If the trial court denies relief on remand, the judgment will be reinstated; if relief is granted, further proceedings will follow. View "People v. Howard" on Justia Law

Victor S. Couzens, the senior pastor of Inspirational Bible Church (IBC), faced a significant decline in church membership and financial troubles following public accusations of an adulterous relationship. In response, church leaders organized a vote to remove him from his position. To enforce this decision, they hired off-duty police officers for the next Sunday service. When Couzens attempted to address the congregation, the officers threatened him with arrest, leading him to leave the church. Couzens subsequently sued the officers, their police chief, and the City of Forest Park, alleging a conspiracy to deny him his constitutional rights.The United States District Court for the Southern District of Ohio granted summary judgment in favor of the defendants. The court found that while the officers' actions could be seen as a seizure under the Fourth Amendment, their actions were not unreasonable. The court also determined that the free exercise claim failed because the police department's policy did not target religious conduct. Without constitutional violations from individual defendants, the court found no merit in the municipal liability and civil conspiracy claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the officers' actions were objectively reasonable given the circumstances and the evidence they had, including a letter indicating Couzens' removal as pastor. The court also found that Couzens failed to establish a violation of his First Amendment rights, as the officers' actions did not reflect state interference in church governance. Consequently, the court upheld the summary judgment on the constitutional, civil conspiracy, and municipal liability claims. View "Couzens v. City of Forest Park, Ohio" on Justia Law

Two young African American boys died in a house fire after two City of Flint firefighters failed to properly search the home. The then-City Fire Chief, Raymond Barton, attempted to discharge the firefighters for gross misconduct. However, Flint’s Mayor, Sheldon Neeley, allegedly intervened to cover up the firefighters' actions to gain support from the firefighters’ union for his re-election. When Barton refused to comply with Neeley’s directives to alter official reports and make false public statements, Neeley fired him.In the United States District Court for the Eastern District of Michigan, Barton filed a lawsuit claiming that his termination was retaliation in violation of his First Amendment rights. The district court denied Neeley’s motion to dismiss based on qualified immunity, leading to this interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Barton plausibly alleged a violation of his First Amendment rights, as public employees cannot be compelled to make false, politically motivated statements on matters of public concern in response to threats of retaliation. The court affirmed the district court’s denial of qualified immunity to Neeley, concluding that Barton’s refusal to alter reports and make false statements was protected speech, and that it was clearly established that such compelled speech and retaliation violated the First Amendment. View "Barton v. Neeley" on Justia Law

Fernando Nunez, Jr., an inmate in Pennsylvania, filed a lawsuit against officials of the Pennsylvania Department of Corrections (DOC) under the Religious Land Use and Institutionalized Persons Act (RLUIPA). Nunez, a devout Muslim, claimed that the DOC violated his religious rights by denying him accommodations to consummate his marriage and have ongoing conjugal visits, engage in congregate prayer with visitors, and undergo a religious circumcision.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of the DOC. The court concluded that the DOC had compelling interests in denying Nunez's requests and that there were no less restrictive alternatives available. The court relied on affidavits from DOC officials, which cited concerns about safety, security, health, and resource constraints. The court found that Nunez failed to disprove that the DOC's policies were the least restrictive means of furthering these interests.The United States Court of Appeals for the Third Circuit reviewed the case and found that the District Court did not properly hold the DOC to its burden under RLUIPA. The Third Circuit concluded that the DOC failed to provide sufficient evidence to support its claims of compelling interests and did not adequately consider less restrictive alternatives. The court emphasized that RLUIPA requires a rigorous and fact-intensive inquiry and that the DOC's "mere say-so" was insufficient to meet this standard. The Third Circuit vacated the District Court's judgment and remanded the case for further proceedings, allowing the DOC to supplement the record to meet its burden under RLUIPA. View "Nunez v. Wolf" on Justia Law

Marlo Spaeth, an individual with Down syndrome, was employed by Wal-Mart for over 15 years. Her work schedule was changed from 12:00 p.m. to 4:00 p.m. to 1:00 p.m. to 5:30 p.m., causing her significant difficulty in adapting due to her disability. Despite requests from Spaeth and her sister to revert to her original schedule, Wal-Mart did not accommodate her, leading to her termination for attendance issues. The Equal Employment Opportunity Commission (EEOC) filed a lawsuit on Spaeth’s behalf under the Americans with Disabilities Act (ADA), alleging failure to accommodate her disability.The United States District Court for the Eastern District of Wisconsin held a jury trial, which resulted in a verdict in favor of the EEOC. The jury awarded Spaeth $150,000 in compensatory damages and $125 million in punitive damages, which the court reduced to $150,000 to comply with the ADA’s damages cap. The court also awarded backpay, prejudgment interest, and compensation for tax consequences, totaling $419,662.59. However, the district court denied the EEOC’s requests for broader injunctive relief, ordering only Spaeth’s reinstatement and communication with her guardian regarding future issues.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the jury’s findings on liability and the awards of compensatory and punitive damages. It held that Wal-Mart was aware of Spaeth’s need for a schedule accommodation due to her Down syndrome and failed to engage in the interactive process required by the ADA. The court found sufficient evidence to support the jury’s award of punitive damages, noting Wal-Mart’s reckless indifference to Spaeth’s rights. The court also upheld the compensatory damages, finding them rationally related to the evidence of Spaeth’s emotional distress and depression.However, the Seventh Circuit vacated the district court’s denial of broader injunctive relief and remanded for reconsideration. The court noted that the district court had incorrectly characterized all requested injunctive relief as “obey the law” injunctions and failed to consider the possibility of recurring discriminatory conduct. The district court was directed to reassess the need for injunctive measures to prevent future violations. View "EEOC v. Wal-Mart Stores East, L.P." on Justia Law

The case involves Kimberly Marroquin, who sued Los Angeles Police Officer DiMaggio Rico and the City of Los Angeles under 42 U.S.C. § 1983, alleging excessive force and negligence after being injured by a less-lethal projectile during a crowd control situation following a Lakers game. Marroquin claimed that the injury caused her substantial physical and emotional harm. The jury found in favor of Marroquin on her excessive force and negligence claims but awarded inconsistent damages: $1.00 against Officer Rico and $1,500,000.00 against the City.The United States District Court for the Central District of California granted a new trial limited to damages under Fed. R. Civ. P. 59(a)(1)(A), citing a miscarriage of justice due to the jury's improper apportionment of damages. The court also denied the defendants' motion for relief from judgment under Fed. R. Civ. P. 60(b)(2), which was based on newly discovered surveillance footage. The court found that the defendants failed to show reasonable diligence in discovering this evidence.The United States Court of Appeals for the Ninth Circuit reviewed the district court's post-trial orders. The Ninth Circuit held that the district court did not abuse its discretion in granting a new trial limited to damages, rejecting the defendants' argument that the liability and damages issues were so interwoven that a damages-only trial violated their Seventh Amendment rights. The court found that the liability issues were distinct and separable from the damages issues and that the jury's confusion was likely due to an improper instruction on the verdict form.The Ninth Circuit also upheld the district court's denial of the Rule 60(b)(2) motion, agreeing that there is no exception to the requirement of reasonable diligence, even if the newly discovered evidence is conclusive. The court affirmed the district court's decisions, maintaining the new trial limited to damages and the denial of relief from judgment based on the newly discovered evidence. View "MARROQUIN V. CITY OF LOS ANGELES" on Justia Law