Justia Civil Rights Opinion Summaries

While incarcerated at High Desert State Prison in Clark County, Brian Caperonis was killed by other inmates. His father, William Joseph Caperonis, acting individually and as the special administrator of Brian’s estate, filed a civil complaint against the Nevada Department of Corrections (NDOC) and several of its employees. The claims included civil rights violations under 42 U.S.C. § 1983, wrongful death, and various negligence claims related to Brian’s death.NDOC moved to dismiss the state law negligence claims, arguing that the estate had failed to exhaust administrative remedies as required by NRS 41.0322 and NRS 209.243. NDOC asserted that, as the estate stands in the shoes of the decedent, it was required to file an administrative claim before pursuing litigation. William opposed, contending that the exhaustion requirement applied only to living inmates and not to the estates of deceased prisoners. The Eighth Judicial District Court denied NDOC’s motion to dismiss, finding that the plain language of the statutes and the relevant administrative regulations did not extend the exhaustion requirement to estates of deceased inmates.The Supreme Court of Nevada reviewed NDOC’s petition for a writ of mandamus. The court held that the administrative exhaustion requirements in NRS 41.0322 and NRS 209.243 do not apply to the estate of a deceased prisoner. The court reasoned that the statutory language is limited to “a person who is or was” in NDOC custody and does not contemplate survival claims by estates. The court also found that the administrative regulations provide no mechanism for an estate to pursue such remedies. Accordingly, the Supreme Court of Nevada denied NDOC’s writ petition, affirming the district court’s decision. View "Department of Corrections v. District Court" on Justia Law

An 18-year-old individual was convicted of second degree felony murder and sentenced to 300 months in prison, with an offender score that included a prior drug possession conviction. The court also imposed over $7,000 in restitution to the Crime Victims Compensation fund, covering part of the victim’s funeral expenses. Years later, following the Washington Supreme Court’s decision in State v. Blake, which invalidated certain drug possession convictions, the individual’s prior conviction was vacated, reducing his offender score and lowering his sentencing range. At the resentencing hearing, the individual specifically requested that the court consider his youth at the time of the offense as a mitigating factor. The resentencing judge declined to do so, stating that the issue of youthfulness was not relevant to the hearing and could be raised elsewhere, and imposed a sentence within the new standard range as recommended by defense counsel.The Washington Court of Appeals reviewed the case and held that, although the resentencing judge had discretion to consider youth as a mitigating factor, any error in failing to do so was harmless because the sentence imposed matched the defense’s request. The Court of Appeals also found that the restitution order was not constitutionally excessive, as it was compensatory rather than punitive.The Supreme Court of the State of Washington reversed the Court of Appeals in part. It held that the resentencing court abused its discretion by failing to meaningfully consider the individual’s youthfulness when specifically asked, as required by precedent. The court clarified that while a judge is not required to impose a lower sentence due to youth, the judge must at least consider it as a mitigating factor. The Supreme Court affirmed the Court of Appeals’ ruling that the restitution was not excessive, as it was solely compensatory. The case was remanded for a new resentencing hearing. View "State v. Ellis" on Justia Law

A two-year-old child, M.B., was placed with foster parents who are members of an Old Order Amish community shortly after his birth. The foster parents had previously adopted M.B.’s three biological sisters, who also reside in their home. Concerns were raised by M.B.’s guardian ad litem regarding the suitability of this placement, primarily because the Amish foster parents would limit M.B.’s formal education to eighth grade, consistent with their religious beliefs. Additional concerns included the lack of regular pediatric care, limited vaccination, restricted exposure to technology, and the potential for racial non-acceptance within the Amish community, as M.B. is biracial.The Circuit Court of Kanawha County reviewed a motion by the guardian ad litem to remove M.B. from the foster home. The court considered evidence and testimony, including the foster father’s statements about education, medical care, and community acceptance. The court also reviewed a special commissioner’s report, which acknowledged the loving and stable environment provided by the foster parents but noted potential limitations related to education, healthcare, and cultural exposure. Ultimately, the circuit court denied the motion to remove M.B., finding that the foster home was stable, loving, and in the child’s best interests, and that the court could not discriminate against the family based on religion or lifestyle.The Supreme Court of Appeals of West Virginia affirmed the circuit court’s decision. The court held that the Foster Child Bill of Rights does not mandate removal from a placement solely because one or more statutory rights may be limited, but instead requires a best-interest-of-the-child analysis considering all relevant factors. The court found that the circuit court’s findings were supported by the record and that M.B.’s placement with the Amish foster parents did not violate his statutory or constitutional rights. View "In re M.B." on Justia Law

A resident of University Heights, Ohio, who practices Orthodox Judaism, sought to use his home for group prayer sessions due to religious obligations and restrictions on travel during the Sabbath. After inviting neighbors to participate in these gatherings, a neighbor complained to city officials, prompting the city’s law director to send a cease-and-desist letter, warning that using the home as a place of religious assembly violated local zoning laws. The resident then applied for a special use permit to operate a house of worship but withdrew his application before the city’s Planning Commission could reach a decision, stating he did not wish to operate a house of worship as defined by the ordinance. Despite withdrawing, he later filed a federal lawsuit against the city and several officials, alleging violations of federal and state law, including constitutional and statutory claims.The United States District Court for the Northern District of Ohio granted summary judgment for the city and its officials. The court found that the plaintiff’s claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the First and Fourteenth Amendments, and the Ohio Constitution were unripe because there was no final decision by the relevant local authorities regarding the application of the zoning ordinance to his property. The court also rejected his Fourth Amendment and Freedom of Access to Clinic Entrances Act (FACE Act) claims on the merits and declined supplemental jurisdiction over a state public records claim.The United States Court of Appeals for the Sixth Circuit affirmed. The court held that most of the plaintiff’s claims were unripe because he withdrew his application before any final decision was made by the city’s zoning authorities, and thus there was no concrete dispute for federal review. The court also held that his facial challenges to the ordinance were forfeited and, in any event, failed as a matter of law. The court further concluded that the Fourth Amendment and FACE Act claims failed on the merits and found no abuse of discretion in declining supplemental jurisdiction over the state law claim. View "Daniel Grand v. City of University Heights, Ohio" on Justia Law

Skye Angel Anne Hennon filed a sworn petition in the Judith Basin Justice Court seeking a temporary order of protection against Matthew Weber for herself, her minor son N.G., and Brian Gonzalez. Hennon alleged that Weber had harassed and stalked her through threatening messages and uninvited visits, and referenced a separate legal dispute in Idaho. The Justice Court issued a temporary order of protection and scheduled a hearing, at which both parties appeared and testified. During the hearing, Weber attempted to cross-examine Hennon, but the court allowed Hennon to decline answering a relevant question and ended the cross-examination. Weber presented his own testimony and attempted to submit exhibits, which the court excluded as hearsay. The Justice Court extended the order of protection for Hennon and N.G. for one year.Weber appealed to the Montana Tenth Judicial District Court, which affirmed the order of protection for Hennon and N.G., but dismissed it as to Gonzalez, noting that Gonzalez, as an adult, needed to seek his own order. The District Court acknowledged deficiencies in the record, including unclear admitted exhibits and unintelligible audio, but relied on the Justice Court’s position to observe the parties and testimony.Weber then appealed to the Supreme Court of the State of Montana. The Supreme Court held that the Justice Court abused its discretion and violated Weber’s procedural due process rights by denying him a meaningful opportunity to cross-examine Hennon on central factual issues. The Court also found that the District Court abused its discretion by affirming the order of protection despite an incomplete and unclear record. The Supreme Court vacated both lower courts’ orders and remanded the case to the Justice Court for a new evidentiary hearing consistent with statutory and due process requirements. View "Hennon v. Weber" on Justia Law

In 2018, the plaintiff contacted police to help resolve a dispute at her home involving her adult children. After officers arrived and de-escalated the situation, a third officer arrived, and a disagreement between the plaintiff and this officer led to her arrest. She was charged with resisting arrest, disorderly conduct, and assault and battery on a police officer. Rather than pleading guilty or going to trial, the plaintiff entered into an agreement under Massachusetts law for three months of pretrial probation, with the understanding that the charges would be dismissed upon successful completion. She did not admit to any wrongdoing or facts, and after completing probation, the charges were dismissed.The plaintiff later filed a lawsuit in state court against the City of Springfield and several police officers, alleging civil rights violations under 42 U.S.C. § 1983, including excessive force during her arrest. The defendants removed the case to the United States District Court for the District of Massachusetts and moved for summary judgment, arguing that the plaintiff’s claims were barred by the doctrine established in Heck v. Humphrey, which prevents § 1983 claims that would impugn a valid criminal judgment. The district court denied summary judgment on this ground for two officers, holding that the Heck bar did not apply because the plaintiff was not convicted.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s decision. The court held that the Heck bar does not apply when there is no underlying criminal conviction or sentence. Because the plaintiff’s charges were dismissed after pretrial probation without any admission of guilt or factual findings, her § 1983 claims could proceed. The case was remanded for further proceedings. View "Aprileo v. Clapprood" on Justia Law

A man was charged with illegal possession of ammunition after police stopped a car in which he was a passenger late at night, citing a non-functioning license plate light and tinted windows. During the stop, officers asked both occupants if they were on parole or probation, ordered them out of the vehicle, and conducted pat searches, citing low lighting and baggy clothing as reasons. A search of a backpack near the passenger seat revealed ammunition and documents with the passenger’s name. The passenger, who had prior felony convictions, was arrested. During the encounter, officers used slang and whistled at both the passenger and two Latino men passing by.The Santa Clara County Superior Court initially denied the passenger’s motion under the California Racial Justice Act (RJA), finding he had not made a prima facie showing that the officers’ actions were motivated by racial bias. After the California Court of Appeal issued an alternative writ requiring reconsideration and a detailed ruling on all claims, the trial court again denied the motion, concluding that the allegations were conclusory or unsupported.The California Court of Appeal, Sixth Appellate District, reviewed the case de novo and held that the passenger had made a prima facie showing under the RJA. The court found that, when considering the totality of the facts—including expert testimony, statistical evidence, and the officers’ language and conduct—there was a substantial likelihood that law enforcement exhibited bias based on race, ethnicity, or national origin. The court clarified that at the prima facie stage, the trial court should not weigh evidence or make credibility determinations, but should accept the truth of the movant’s factual allegations unless they are conclusory or contradicted by the record. The appellate court issued a writ directing the trial court to hold an evidentiary hearing on the RJA motion. View "Hernandez v. Superior Court" on Justia Law

A police union sought an injunction requiring the City of Los Angeles to comply with a state law mandating that anyone filing a complaint of police misconduct must first read and sign an advisory warning that knowingly filing a false complaint is a crime. The law, Penal Code section 148.6(a), singles out complaints against peace officers for this treatment, and its legislative history shows it was enacted to address concerns about reputational and professional harm to officers from false complaints, as well as the administrative burden of investigating such claims.Previously, the Los Angeles County Superior Court granted the injunction, finding itself bound by the California Supreme Court’s earlier decision in People v. Stanistreet, which had upheld the constitutionality of section 148.6(a). The California Court of Appeal affirmed, also relying on Stanistreet, despite several federal court decisions—including Chaker v. Crogan and Hamilton v. City of San Bernardino—holding that the statute violated the First Amendment.The Supreme Court of California reviewed the case and reconsidered its prior holding in light of subsequent U.S. Supreme Court decisions, including United States v. Alvarez and Free Speech Coalition, Inc. v. Paxton. The court held that section 148.6(a) is a content-based regulation within a proscribable category of speech (defamation) but, as drafted, it incidentally burdens protected speech by deterring truthful or well-intentioned complaints of police misconduct. Applying intermediate scrutiny, the court found the statute was not narrowly tailored to serve the government’s interests and burdened substantially more speech than necessary. The Supreme Court of California reversed the Court of Appeal’s judgment and remanded the case for further proceedings. View "L.A. Police Protective League v. City of L.A." on Justia Law

Donovan Lewis, a twenty-year-old Black man, was fatally shot by a Columbus police officer while in bed at his apartment during an attempted arrest on outstanding warrants. His estate filed a civil rights lawsuit under 42 U.S.C. § 1983 against the City of Columbus and the police chief, alleging that the city’s police department maintained a policy or custom of racially discriminatory policing and excessive force, which led to Lewis’s death. The complaint sought damages and permanent injunctive relief, including specific reforms to police disciplinary and employment practices that were rooted in the collective bargaining agreement (CBA) negotiated by the Fraternal Order of Police (FOP), Capitol City Lodge #9.After the estate initiated the suit, FOP moved to intervene as of right or, alternatively, permissively, arguing that the proposed reforms would violate the CBA and impact its legal obligations as the exclusive bargaining representative for Columbus police officers. The United States District Court for the Southern District of Ohio denied FOP’s motion without prejudice, finding that FOP had only a limited interest in the remedial phase and that any liability-phase interest was adequately represented by the City. The court invited FOP to renew its motion if the estate prevailed or if settlement discussions occurred.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of intervention. The Sixth Circuit held that FOP satisfied all requirements for intervention as of right under Federal Rule of Civil Procedure 24(a)(2): FOP demonstrated a substantial legal interest in the subject matter, impairment of its interests absent intervention, and that the City may not adequately represent those interests. The court concluded that FOP should be allowed to intervene in all phases of the litigation and reversed the district court’s denial of intervention. View "Estate of Lewis v. City of Columbus, Ohio" on Justia Law

A 12-year-old boy was killed by police officers during an attempt to rescue him from a neighbor who had already killed the boy’s mother and housekeeper, gravely wounded his sister, and was holding the boy hostage in a vehicle. The officers responded to multiple 911 calls, surrounded the vehicle, and attempted to negotiate with the hostage-taker, who was armed and making threats against the child’s life. After the hostage-taker was shot and killed by an officer, other officers fired additional shots, which resulted in the boy’s death.The boy’s father, siblings, and estate filed a lawsuit in the United States District Court for the District of Nevada against the city, police department, and individual officers. They alleged violations of the Fourth Amendment (excessive force), Fourteenth Amendment (substantive due process), a Monell claim for failure to train, and state law claims. The district court dismissed the federal claims with prejudice, finding that the officers had not seized the boy for Fourth Amendment purposes, had not acted with deliberate indifference or intent to harm for Fourteenth Amendment purposes, and that the Monell claim failed in the absence of a constitutional violation.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that the officers did not violate the boy’s Fourth Amendment rights because their actions during the active hostage situation did not constitute a seizure, and even if a violation had occurred, qualified immunity would apply as the right was not clearly established. The court also found no Fourteenth Amendment violation, as the officers’ actions did not shock the conscience or demonstrate deliberate indifference, and qualified immunity would apply. The Monell claim failed due to the absence of an underlying constitutional violation. View "HAWATMEH V. CITY OF HENDERSON" on Justia Law