Justia Civil Rights Opinion Summaries

Arthur Lee Burton was convicted of capital murder and sentenced to death in June 1998 for kidnapping, sexually assaulting, and strangling a woman in Houston, Texas. His conviction was affirmed by the Texas Court of Criminal Appeals, but his sentence was vacated and remanded for a new trial on punishment. Upon retrial, he was again sentenced to death, and this sentence was affirmed. Burton pursued state and federal habeas relief, which were all denied.Burton recently filed three challenges to his scheduled execution in Texas state court, including motions to withdraw his execution order and a habeas petition alleging constitutional violations. These challenges were rejected by the Texas Court of Criminal Appeals. Subsequently, Burton sought authorization from the United States Court of Appeals for the Fifth Circuit to file a successive federal habeas petition under 28 U.S.C. § 2244(b) and moved to stay his execution.The United States Court of Appeals for the Fifth Circuit denied both motions. The court held that Burton's petition was untimely, as it was filed well beyond the one-year limitation period prescribed by § 2244(d). Burton's reliance on Atkins v. Virginia and Moore v. Texas was insufficient to excuse the delay, as both cases were decided long before his current motion. The court also rejected Burton's arguments for equitable tolling and actual innocence, finding that he had not pursued his rights diligently and that his claims were not supported by extraordinary circumstances. Consequently, the court concluded that Burton failed to meet the requirements of § 2244 and denied his motion to stay execution. View "In re Burton" on Justia Law

Law enforcement officers executed a search warrant at Lee Marvin Harris, Sr.'s home, discovering a significant amount of cocaine in an old Cadillac parked in the yard. Harris, Sr. was arrested for possession with intent to distribute and spent five months in pretrial detention before charges were dismissed. He then sued the Town of Southern Pines and the officers involved, alleging malicious prosecution under the Fourth Amendment and fabrication of evidence under the Fourteenth Amendment, claiming officers omitted material evidence from prosecutors and grand juries.The United States District Court for the Middle District of North Carolina granted summary judgment in favor of the defendants. The court found that probable cause existed for Harris, Sr.'s arrest based on the discovery of cocaine on his property and dismissed the fabrication of evidence claim, reasoning that such claims are not viable if the plaintiff was not convicted. Harris, Sr. appealed the decision.The United States Court of Appeals for the Fourth Circuit reviewed the case and found genuine disputes of material fact regarding whether Harris, Sr. was arrested and charged without probable cause. The court held that the officers were not entitled to qualified immunity for the Fourth Amendment malicious prosecution claim. Additionally, the court determined that a plaintiff who was arrested and detained but not convicted could still state a Fourteenth Amendment fabrication of evidence claim. Consequently, the court reversed the district court's summary judgment on the Fourth Amendment malicious prosecution claim, vacated the summary judgment on the Fourteenth Amendment fabrication of evidence claim, and remanded for further proceedings. The court affirmed the district court's summary judgment on the state law malicious prosecution claim, the failure to intervene claim, and the Monell claim against the Town of Southern Pines and the Chief of Police. View "Harris v. Town of Southern Pines" on Justia Law

A twelve-year-old boy named Maxwell was abused and killed by his father and stepmother. His mother, Sara Coon, sued Lebanon County and several county officials, alleging that the county knew about the abuse and had a state-law duty to protect Maxwell. The complaint stated that the county's Children and Youth Services agency failed to act despite multiple warnings about the abuse.The United States District Court for the Middle District of Pennsylvania dismissed the federal claims brought under 42 U.S.C. § 1983, concluding that Pennsylvania’s Child Protective Services Law did not create a property interest in having the county agency protect Maxwell from child abuse. The court also remanded the state-law claims to state court.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that due process protects interests in life, liberty, or property, and to state a claim for violating procedural due process, a plaintiff must show a legitimate claim of entitlement to a protected property interest. The court found that Pennsylvania law did not create such a property interest in having a county agency protect a child from abuse. The court compared this case to Town of Castle Rock v. Gonzales and Burella v. City of Philadelphia, where similar statutory language did not create a property interest. Consequently, the Third Circuit affirmed the District Court’s order dismissing the federal claims and remanding the state claims to state court. View "Coon v. County of Lebanon" on Justia Law

An inmate in the Arkansas Department of Corrections (ADC) filed a pro se 42 U.S.C. § 1983 action, alleging that several ADC employees retaliated against him for exercising his First Amendment rights. The inmate claimed retaliation occurred after he filed a grievance, circulated a memorandum encouraging other inmates to file grievances against a new administrative directive, and threatened a lawsuit. The directive in question imposed a three-page limit on non-privileged correspondence between inmates and non-incarcerated individuals. The inmate was charged with rule violations, placed in isolation, and later moved to administrative segregation.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants, concluding that they had valid, non-retaliatory reasons for their actions, as the inmate had violated prison rules. The district court also denied the inmate's request for an extension of time to file his own summary judgment motion, citing a lack of good cause and the age of the case. The inmate appealed both decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court’s grant of summary judgment, finding that the inmate’s circulation of the memorandum was protected conduct under the First Amendment and that there was insufficient evidence to demonstrate a security concern justifying the disciplinary actions. The court also found that the district court erred in relying on a written charge of a rule violation that was dismissed on procedural grounds and on the inmate’s deposition testimony given years later. However, the court affirmed the district court’s denial of the inmate’s request for an extension of time to file a summary judgment motion, finding no abuse of discretion. View "Lamar v. Payne" on Justia Law

A high school football coach's contract was not renewed by the Valdosta Board of Education in 2020. The vote split along racial lines, with all white members voting to renew and all black members voting against renewal. The coach believed the decision was racially motivated.In 2020, the coach sued the five black board members individually under 42 U.S.C. §§ 1981 and 1983, seeking monetary damages. The district court denied the board members' motions to dismiss based on qualified immunity, but the Eleventh Circuit reversed, finding the coach failed to state a claim. The case was remanded for dismissal.In 2021, the coach filed a new lawsuit against the same board members and the Board itself, this time under Title VII of the Civil Rights Act of 1964. The new complaint included more detailed allegations but was based on the same core facts. The district court granted summary judgment for the Board, ruling that the new lawsuit was barred by res judicata because the Board was in privity with the individual board members and the two cases involved the same cause of action.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court held that the Board was in privity with the individual board members because they acted as the Board when they voted not to renew the coach's contract. The court also found that both lawsuits arose from the same nucleus of operative facts, thus meeting the criteria for res judicata. View "Rodemaker v. City of Valdosta Board of Education" on Justia Law

Carl Langston was convicted of possessing a firearm in violation of 18 U.S.C. § 922(g)(1), the felon-in-possession statute. Langston argued that this statute is unconstitutional under the Second Amendment as applied to him, given his prior convictions for theft and drug trafficking under Maine law. He also challenged the district court's denial of his motion to suppress evidence obtained during a police stop and several sentencing decisions.The United States District Court for the District of Maine denied Langston's motion to suppress, finding that the police stop was based on reasonable suspicion. Langston then entered a conditional guilty plea, reserving the right to appeal the suppression ruling. At sentencing, the district court applied a four-level enhancement for possessing a firearm during a felony assault on an officer and denied Langston a reduction for acceptance of responsibility, citing his conduct during pretrial release.The United States Court of Appeals for the First Circuit reviewed Langston's claims. The court held that Langston's Second Amendment challenge failed under the plain-error standard because it was not "clear" or "obvious" that § 922(g)(1) is unconstitutional as applied to him. The court noted that the Supreme Court has consistently referred to felon-in-possession laws as "presumptively lawful."The court also upheld the district court's denial of the motion to suppress, agreeing that the totality of the circumstances gave rise to reasonable suspicion for the police stop. Additionally, the court found no plain error in the application of the sentencing enhancement for felony assault on an officer and ruled that the district court did not abuse its discretion in relying on hearsay evidence to conclude that Langston violated his pretrial release conditions. Finally, the court affirmed the denial of the acceptance-of-responsibility credit, noting the similarities between Langston's conduct at the time of his arrest and during his pretrial release.The First Circuit affirmed Langston's conviction and sentence. View "US v. Langston" on Justia Law

Christopher Drew was arrested after officers responded to a harassment complaint from his neighbor, who reported that Drew had threatened her and her child. When officers arrived at Drew's apartment, they found him in a confrontation with another woman. During the arrest, Officer Hemsted pepper-sprayed Drew without warning after Drew refused to comply with orders and warned the officer not to touch him. Drew later pleaded guilty to second-degree harassment and subsequently sued the officers and the City of Des Moines under 42 U.S.C. § 1983 for excessive force, failure to intervene, and Monell liability.The United States District Court for the Southern District of Iowa granted summary judgment in favor of the defendants, finding that Officer Hemsted's use of force was objectively reasonable. The court concluded that the officers did not violate Drew's Fourth Amendment rights and dismissed all claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Officer Hemsted was entitled to qualified immunity because it was not clearly established that using pepper spray in this context violated Drew's constitutional rights. The court noted that Drew was suspected of a serious crime involving threats of violence and was noncompliant during the arrest. The court distinguished this case from others involving less severe crimes and minimal safety threats. Consequently, the court also found that Officer Ulin and the City of Des Moines were not liable, as they were not on fair notice that their actions were unconstitutional. The Eighth Circuit affirmed the district court's judgment and granted the motion to supplement the record with bodycam footage. View "Drew v. City of Des Moines" on Justia Law

David Efron and Madeleine Candelario were involved in a divorce proceeding in Puerto Rico, during which Efron was ordered to pay Candelario $50,000 per month. After the divorce was finalized, Candelario began a relationship with Judge Cordero, and Efron alleges that Candelario, her attorney, and Judges Cordero and Aponte conspired to reinstate the payments through a corrupt scheme. Efron claims this resulted in Candelario receiving approximately $7 million. Efron filed a federal lawsuit against Candelario and her attorney, asserting claims for deprivation of procedural due process, conspiracy to deny civil rights, civil conspiracy, and unjust enrichment.The United States District Court for the Southern District of Florida dismissed Efron’s complaint for lack of subject matter jurisdiction, citing the Rooker-Feldman doctrine. The court found that Efron’s claims were inextricably intertwined with the Puerto Rico court’s judgment and that granting relief would effectively nullify that judgment. The district court also rejected Efron’s argument that his claims fell under a fraud exception to the Rooker-Feldman doctrine.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s dismissal. The Eleventh Circuit held that the Rooker-Feldman doctrine barred Efron’s claims because they essentially sought to challenge the state court’s judgment. The court concluded that Efron’s claims for damages were not independent of the state court’s decision but were directly related to it, as they required the federal court to review and reject the state court’s judgment. Therefore, the district court correctly dismissed the complaint for lack of subject matter jurisdiction. View "Efron v. Candelario" on Justia Law

In August 2019, Eric Toon led Lieutenant Christopher Zerkle on a high-speed chase before returning to his home, where his girlfriend, Taylor Quinn, was sleeping. Zerkle and other officers, including Sergeants Paxton Lively and Rick Keglor, and Deputies Brandon Kay and Jamie Miller, arrived at Toon’s residence. The officers knocked on the door, which eventually opened outward, leading them to enter the home. Toon then broke a window, jumped out with an AR-15, and was fatally shot by Zerkle and another officer. Quinn, who followed Toon out of the window, was also injured.The United States District Court for the Southern District of West Virginia dismissed some claims and granted summary judgment in favor of the officers on the remaining claims. The court found that the officers reasonably believed they had consent to enter the home when the door opened and that Zerkle’s use of deadly force against Toon was justified. The court also concluded that Quinn’s injuries were accidental and not the result of intentional excessive force.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that factual disputes precluded summary judgment on the warrantless entry claims and Quinn’s excessive force, battery, and trespass claims. The court held that the officers could not assume consent to enter the home merely because the door opened. The court also determined that there was sufficient evidence for a jury to find that Zerkle intentionally shot Quinn. The court affirmed the district court’s decision on the remaining claims, including the excessive force claim related to Toon and the failure to intervene claim against Zerkle. The case was reversed in part, affirmed in part, and remanded for further proceedings. View "Quinn v. Zerkle" on Justia Law

Dominique Ramsey and Travis Sammons were incarcerated for over five years for the murder of Humberto Casas. Their convictions were overturned by Michigan appellate courts due to an improper identification, leading to the dismissal of the case and their release. Ramsey and Sammons then sued David Rivard, a Michigan State Police sergeant, under federal and state law for malicious prosecution, fabrication of evidence, and unduly suggestive identification. The district court denied Rivard’s motion for summary judgment, rejecting his claims of absolute and qualified immunity for the federal claims and governmental immunity for the state law claim. Rivard appealed.The United States District Court for the Eastern District of Michigan denied Rivard’s motion for summary judgment, finding that he was not entitled to absolute or qualified immunity for the federal claims nor to governmental immunity for the state law claim. The court determined that there were genuine disputes of material fact regarding Rivard’s conduct and the reliability of the identification procedure he oversaw. Rivard then appealed to the United States Court of Appeals for the Sixth Circuit.The United States Court of Appeals for the Sixth Circuit dismissed Rivard’s appeal regarding the denial of qualified immunity for the federal malicious prosecution and fabrication of evidence claims due to lack of appellate jurisdiction. The court affirmed the district court’s denial of summary judgment on the remaining claims. The court held that Rivard was not entitled to absolute immunity for his pretrial conduct and that there were genuine disputes of material fact regarding his good faith, precluding summary judgment on the state law malicious prosecution claim. The court also found that a jury could determine the show-up identification was unduly suggestive and unreliable, thus violating clearly established law. View "Ramsey v. Rivard" on Justia Law