Justia Civil Rights Opinion Summaries

Ryan Smith was shot and killed by Seattle police officers Christopher Myers and Ryan Beecroft during a response to a 911 call from Smith's girlfriend, Katy Nolan, who reported that Smith was threatening to kill both himself and her with a knife. When the officers arrived, they kicked in the door to Smith's apartment, and within 5.87 seconds, they shot Smith, who was holding a pocketknife. Smith raised his right arm across his chest and took a step forward before being shot. The officers did not issue any warnings before using deadly force.The United States District Court for the Western District of Washington denied the officers' motion for partial summary judgment based on qualified immunity. The district court found that there were factual disputes regarding whether a reasonable officer would have believed Smith posed an immediate threat and whether less drastic measures were feasible. The court concluded that the law was clearly established that officers may not use deadly force against suspects who do not pose an immediate threat.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The Ninth Circuit held that it had jurisdiction over the interlocutory appeal and that, viewing the evidence in the light most favorable to the plaintiffs, the officers were not entitled to qualified immunity. The court determined that a reasonable juror could conclude that Smith did not pose an immediate threat to the officers or others, and that the use of deadly force was not justified. The court emphasized that it was clearly established law that a fatal shooting under these circumstances violated the Fourth Amendment. The Ninth Circuit affirmed the district court's denial of qualified immunity. View "JOHNSON V. MYERS" on Justia Law

Elijah Jackson, a Black man, was charged with carrying a loaded firearm after police found a handgun during a search of the car he was driving. Jackson filed a motion under the California Racial Justice Act of 2020, arguing that the police stopped and searched his car due to racial bias. The superior court denied his motion, stating that Jackson failed to establish a prima facie violation under the Racial Justice Act.The superior court found that the police officers were conducting a saturation patrol in a high-crime area and stopped Jackson for having illegally tinted windows. The officers observed Jackson and his brother, who were wearing clothing associated with gang members, and conducted a traffic stop. During the stop, the officers found a baseball bat in the car and, after a search, discovered an unregistered loaded firearm. Jackson argued that the stop and search were racially motivated, supported by statistical evidence showing racial disparities in traffic stops and searches by the San Diego Police Department (SDPD).The Court of Appeal, Fourth Appellate District, reviewed the case and concluded that Jackson had produced facts that, if true, established a substantial likelihood of a violation of the Racial Justice Act. The court noted the statistical evidence showing racial disparities in SDPD's traffic stops and searches, as well as Jackson's and his brother's repeated stops for the same tinted windows without receiving citations. The court also considered the officers' focus on Jackson's and his brother's appearance and the neighborhood they were in, which suggested implicit bias.The Court of Appeal issued a writ of mandate directing the superior court to grant an evidentiary hearing to consider Jackson's motion under the Racial Justice Act. The court emphasized the importance of addressing implicit bias in the criminal justice system and ensuring that race does not play a role in seeking or obtaining convictions. View "Jackson v. Super. Ct." on Justia Law

Jack William Morgan, a Messianic Jew, purchased a turkey log from the commissary at the Federal Correctional Institution (FCI) Thomson in May 2021, which led to the suspension of his kosher diet approval for thirty days by the institutional chaplain. Morgan claimed this forced him to choose between starvation and violating his religious beliefs, and he chose starvation. After exhausting administrative remedies, he sued the Federal Bureau of Prisons (BOP) and the prison warden, Andrew Ciolli, seeking changes to dietary policies and monetary damages under the Religious Freedom Restoration Act (RFRA). Morgan has since been transferred to a different BOP facility.The United States District Court for the Northern District of Illinois dismissed Morgan’s complaint with prejudice for failure to state a claim. The court found that Morgan did not provide sufficient factual allegations to show that the BOP’s dietary policies substantially burdened his religious exercise. Additionally, the court noted that the BOP is immune from suits for damages under RFRA and that Morgan’s complaint did not include allegations about Ciolli’s conduct.The United States Court of Appeals for the Seventh Circuit reviewed the case and focused on two threshold issues: subject-matter jurisdiction and sovereign immunity. The court determined that Morgan did not adequately allege standing to pursue his claim for injunctive relief, as his threat of future injury was too speculative. Furthermore, the court held that federal sovereign immunity barred Morgan’s claim for monetary damages, as RFRA does not waive the federal government’s sovereign immunity against damages suits. The court affirmed the district court’s dismissal but modified the judgment to reflect a jurisdictional dismissal. View "Morgan v BOP" on Justia Law

Breion Woodson was convicted in Wisconsin state court on charges of firearm and drug possession and sentenced to 19 years in prison. During sentencing, the government presented a video from social media showing men with guns and drugs, which the judge used to assess Woodson's character and danger to the community. Woodson argued that he was misidentified in the video, but the judge denied his motion for a new sentencing hearing. The Wisconsin Court of Appeals affirmed, stating Woodson failed to prove he was not the man in the video.Woodson then filed a federal habeas corpus petition in the Eastern District of Wisconsin, introducing booking photos from the time of his sentencing that suggested he was not the man in the video. However, the district court ruled it could not consider the photos since they were not presented in state court and denied his petition, finding the state appellate court's decision reasonable based on the evidence it had.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that under the Antiterrorism and Effective Death Penalty Act (AEDPA), habeas relief is unavailable unless the state court's decision was contrary to or an unreasonable application of federal law or based on an unreasonable determination of facts. The court found that Woodson's claim was not procedurally defaulted and that the actual innocence exception did not apply to his case. The court also ruled that it could not consider the new evidence (booking photos) under AEDPA's strict limitations. Consequently, the Seventh Circuit affirmed the district court's denial of Woodson's habeas petition. View "Woodson v Mlodzik" on Justia Law

Kurt Beathard, a football coach at Illinois State University (ISU), was terminated from his position as offensive coordinator after posting a handwritten message on his office door that read, "All Lives Matter to Our Lord & Savior Jesus Christ." This occurred during a period of tension and unrest on the ISU campus following the death of George Floyd. Beathard alleges that his termination was due to this personal speech, which he claims is protected by the First Amendment.In the District Court for the Central District of Illinois, Beathard filed a section 1983 action against Larry Lyons, the Athletic Director, and Brock Spack, the head football coach, asserting that his termination violated his First Amendment rights. The defendants moved to dismiss the complaint under Rule 12(b)(6), arguing that they were entitled to qualified immunity because it was not clear that Beathard's speech was protected as personal rather than official speech. The district court denied the motion to dismiss, stating that factual development was necessary before resolving the qualified immunity question.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court concluded that it lacked jurisdiction to hear the appeal because the district court had not made a definitive ruling on the qualified immunity defense but had instead postponed the decision, indicating that further factual development was needed. The Seventh Circuit emphasized that interlocutory orders, such as the denial of a motion to dismiss, are generally not immediately appealable unless they conclusively determine the disputed question. Consequently, the appeal was dismissed for want of appellate jurisdiction. View "Beathard v. Lyons" on Justia Law

David Paul Planchard was convicted by a jury of stalking Debra Doe and violating a protective order. Planchard and Doe had a relationship from 1997 to 2000 and had a son together in 2006. Despite a restraining order issued in 2020, Planchard continued to harass Doe through public Facebook posts from 2016 to 2023. These posts included threats, derogatory comments, and references to Doe's past trauma. Planchard also showed up at Doe's house in May 2023, violating the protective order.The Superior Court of Sacramento County found Planchard guilty of stalking and violating a protective order. The jury determined that Planchard's actions, including his Facebook posts and visit to Doe's house, constituted a credible threat and harassment. The court sentenced him to five years for stalking and a stayed term of six months for violating the protective order.The California Court of Appeal, Third Appellate District, reviewed the case. Planchard argued that his Facebook posts did not constitute direct contact and thus could not be considered harassment under the stalking statute. The court disagreed, citing precedent that indirect threats and harassment through third parties or public posts can still meet the statutory requirements for stalking. The court found sufficient evidence to support the jury's verdict, noting that the posts were intended to harass and threaten Doe, and it was reasonably foreseeable that she would see them.The court also addressed Planchard's claims of ineffective assistance of counsel, finding no merit in his arguments. The court concluded that the Facebook posts were relevant and admissible, and that any failure to object by his counsel did not constitute ineffective assistance. The judgment of the Superior Court was affirmed. View "P. v. Planchard" on Justia Law

Chanon Miller was arrested by deputies from the Palm Beach County Sheriff’s Office for simple battery against her ex-fiancé. She subsequently sued the Sheriff’s Office and unnamed deputies, alleging violations of her constitutional right to be free from unreasonable seizure, including claims of false arrest, false imprisonment, and malicious prosecution. Miller's complaint was amended to name specific deputies as defendants.The United States District Court for the Southern District of Florida denied the deputies' motion to dismiss based on qualified immunity, stating that the issue was more appropriately resolved at the summary judgment stage or later in the proceedings. The court found that Miller's allegations were sufficient to state a plausible claim for relief and allowed her to file an amended complaint naming the appropriate defendants. The district court reiterated its position when the deputies renewed their motion to dismiss after being named in the amended complaint.The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that the district court erred by failing to adjudicate the defense of qualified immunity at the motion to dismiss stage. The appellate court emphasized that qualified immunity is an immunity from suit, not just a defense to liability, and must be resolved at the earliest possible stage in litigation. The court vacated the district court’s order and remanded the case with instructions to rule on the deputies' entitlement to qualified immunity, requiring a claim-by-claim and defendant-by-defendant analysis. View "Miller v. Ramirez" on Justia Law

Christopher Kee was convicted of assault with a dangerous weapon in Indian country following an altercation with his then-girlfriend, Candace Chinchillas, in April 2020. The couple had a tumultuous relationship marked by excessive drinking and mutual accusations of abuse. Kee claimed that the stabbing incident was an act of self-defense, while Chinchillas described it as a violent attack. Kee was acquitted of three other counts of assault, which had more corroborative evidence, but was convicted on Count 2, which relied heavily on the conflicting testimonies of Kee and Chinchillas.The United States District Court for the District of New Mexico presided over Kee's trial. Kee did not object during the trial to the prosecution's use of his post-Miranda silence to impeach his testimony. After being convicted and sentenced, Kee filed a timely appeal, arguing that his due process rights were violated under Doyle v. Ohio, which prohibits the use of a defendant's post-Miranda silence for impeachment purposes.The United States Court of Appeals for the Tenth Circuit reviewed Kee's appeal. The court agreed with Kee that the prosecution's repeated references to his post-Miranda silence constituted a clear violation of Doyle. The court applied the plain error review standard, which requires showing that the error was plain, affected substantial rights, and seriously affected the fairness, integrity, or public reputation of judicial proceedings. The court found that the Doyle violation affected Kee's substantial rights because the case hinged on the credibility of Kee and Chinchillas, and the improper impeachment could have influenced the jury's verdict.The Tenth Circuit vacated Kee's conviction and sentence and remanded the case for further proceedings consistent with its opinion. View "United States v. Kee" on Justia Law

In the early morning of November 1, 2019, a group of law enforcement officers, including Task Force Officer (TFO) Clarence Belton and Charlotte-Mecklenburg Police Officer Heather Loveridge, attempted to execute a search warrant at the house of a suspect, Larry McConneyhead, in Charlotte, North Carolina. During the operation, McConneyhead fled into his house, and a confrontation ensued. TFO Belton was accidentally shot by Officer Loveridge, who mistook him for the suspect. Belton suffered severe injuries, leading to multiple surgeries and permanent disability.The case was initially filed in North Carolina state court and then removed to the United States District Court for the Western District of North Carolina. Belton alleged excessive force under 42 U.S.C. § 1983 and several state law claims against Officer Loveridge and the City of Charlotte. Officer Loveridge moved for summary judgment, asserting qualified immunity for the federal claim and public officers’ immunity for the state claims. The district court denied her motion, citing genuine disputes of material fact regarding the circumstances of the shooting.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court failed to conduct the proper analysis for determining qualified immunity, which requires identifying the specific constitutional right violated and whether that right was clearly established at the time of the incident. The Fourth Circuit vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to apply the correct legal standards for qualified immunity and public officers’ immunity. View "Belton v. Loveridge" on Justia Law

Dawn Lui, a longtime employee of the United States Postal Service (USPS), alleged disparate treatment, a hostile work environment, and unlawful retaliation under Title VII of the Civil Rights Act. Lui, a woman of Chinese ethnicity, claimed she was targeted with false complaints and grievances by employees at the Shelton Post Office due to her race, sex, and national origin. She was demoted from her position as Postmaster in Shelton, Washington, to a lower-paying Postmaster position in Roy, Washington, and replaced by a white man. Lui filed an informal discrimination complaint through USPS’s Equal Employment Opportunity (EEO) System and later a formal EEO complaint.The United States District Court for the Western District of Washington granted summary judgment to USPS on all of Lui’s claims. The court found that Lui failed to establish a prima facie case of discrimination, did not exhaust her administrative remedies for her hostile work environment claim, and failed to establish a causal connection for her retaliation claim.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court’s summary judgment on Lui’s disparate treatment claim, holding that Lui established a prima facie case of discrimination by showing she was replaced by a white man, which gave rise to an inference of discrimination. The court also found a genuine dispute of material fact about whether the decision to demote Lui was influenced by subordinate bias.The Ninth Circuit vacated the district court’s summary judgment on Lui’s hostile work environment claim, concluding that Lui exhausted her administrative remedies and remanded the case for the district court to address the merits of this claim. However, the court affirmed the district court’s grant of summary judgment on Lui’s retaliation claim, finding that Lui failed to establish a causal connection between her protected activity and the demotion. View "LUI V. DEJOY" on Justia Law