Justia Civil Rights Opinion Summaries

Residents of Humboldt County filed a putative class action under 42 U.S.C. § 1983, alleging that the County’s system of administrative penalties and fees for cannabis abatement violates the Eighth Amendment’s Excessive Fines Clause. The County Code imposes daily fines of $6,000 to $10,000 for illegal cannabis cultivation. Plaintiffs claimed that the County charges landowners based on imprecise data or previous owners' conduct, causing emotional distress and financial burdens due to ongoing penalties and abatement costs.The United States District Court for the Northern District of California dismissed the case, concluding that plaintiffs lacked standing as they had not paid any fines, rendering the Eighth Amendment claim unripe. The court also found both facial and as-applied challenges untimely, reasoning that the statute of limitations began when the ordinance was enacted.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that plaintiffs’ claim under the Excessive Fines Clause was constitutionally ripe and that they had standing due to the imposition of penalties causing concrete injuries, including emotional distress and financial expenses. The court also found that prudential ripeness considerations supported allowing the litigation to proceed. The court determined that the statute of limitations for facial challenges begins when plaintiffs know of the actual injury, not when the ordinance is enacted. Thus, some plaintiffs’ facial challenges were timely. The court also found that several plaintiffs had timely as-applied challenges, except for Cyro Glad, whose claim was untimely.On the merits, the Ninth Circuit held that plaintiffs plausibly alleged a violation of the Excessive Fines Clause, as the penalties and demolition orders were punitive and potentially excessive. The court reversed the district court’s dismissal of the Eighth Amendment claim and remanded for further proceedings, affirming the dismissal only for Cyro Glad’s as-applied claim. View "THOMAS V. COUNTY OF HUMBOLDT" on Justia Law

A Black man, known for his career in the NFL, was accused by an intellectually disabled woman of raping her at gunpoint during a babysitting job interview at his home. The jury found him guilty of forcible rape, forcible oral copulation, and false imprisonment, with firearm use in the first two offenses. He was sentenced to 15 years to life in prison. The prosecution argued that the police did not search his house due to his fame and race, suggesting a search would have caused controversy.The trial began in March 2020 but was paused due to the COVID-19 pandemic, resuming three months later. The jury acquitted him on two counts related to the victim's incapacity to consent. The trial court sentenced him in October 2020. The defendant appealed, arguing that the prosecution's statements violated the California Racial Justice Act of 2020 by appealing to racial bias.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court found that the prosecution violated the Racial Justice Act by explicitly asserting that the defendant's race influenced the police's decision not to search his house, implying he gained an undeserved advantage at trial because he was Black. The court concluded that the prosecution's statements constituted racially discriminatory language under Penal Code section 745, subdivision (a)(2). The court held that Penal Code section 745, subdivision (e)(2)(A) precludes harmless error analysis and mandates vacating the conviction and sentence. Consequently, the court reversed the judgment, vacated the conviction and sentence, and remanded for new proceedings consistent with the Racial Justice Act. View "P. v. Stubblefield" on Justia Law

Krish Singh was shot and seriously injured by Officer Brittany Smith-Petersen in Phoenix, Arizona. Smith-Petersen and another officer, Annie Batway, responded to a report of an attempted robbery with a knife. Upon arrival, Singh held a knife to his own neck and asked the officers to shoot him. Despite commands to drop the knife, Singh did not comply, and Smith-Petersen shot him. Singh sued the City of Phoenix, Smith-Petersen, and Batway, alleging excessive force under 42 U.S.C. § 1983 and various state law claims.The United States District Court for the District of Arizona granted summary judgment in favor of Smith-Petersen on the § 1983 claim, holding that she was protected by qualified immunity. The court found that although a reasonable jury could find a constitutional violation, there was no clearly established law indicating that her use of force was objectively unreasonable. The district court remanded the state law claims to state court for resolution.The United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment on the § 1983 claim, holding that the case of Glenn v. Washington County, which involved similar facts, provided clearly established law that should have put Smith-Petersen on notice that her use of deadly force was potentially unreasonable. The Ninth Circuit also reversed the district court’s order remanding the state law claims and remanded for reconsideration of whether to exercise supplemental jurisdiction over those claims. The court dismissed Smith-Petersen’s cross-appeal for lack of jurisdiction, as it challenged the district court’s determination of genuine factual disputes, which is not reviewable on appeal. View "SINGH V. CITY OF PHOENIX" on Justia Law

Amity Dimock, the mother of Kobe Dimock-Heisler, sued the City of Brooklyn Center and four police officers, alleging unconstitutional warrantless entry and use of deadly force. The incident began when Kobe's grandfather, Erwin Heisler, called 911 reporting that Kobe had threatened him with a knife and hammer. When officers arrived, they entered the home without a warrant, leading to a confrontation where Kobe, holding a knife, was shot and killed by officers.The United States District Court for the District of Minnesota granted summary judgment in favor of the officers, citing qualified immunity. The court found that the officers reasonably believed exigent circumstances justified their warrantless entry and that they had probable cause to believe Kobe posed an immediate threat, justifying the use of deadly force. Dimock appealed the decision, challenging the grant of qualified immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the officers were entitled to qualified immunity. The court determined that the officers' belief in the existence of exigent circumstances was reasonable given the information they had, including Kobe's previous threats and mental health history. Additionally, the court found that the use of deadly force was justified as the officers had probable cause to believe Kobe posed an immediate threat to his grandmother and the officers, even though Kobe was only holding the knife and not actively attacking anyone at the moment of the shooting. The court concluded that the rights asserted by Dimock were not clearly established in this context, thus affirming the summary judgment in favor of the officers. View "Dimock v. City of Brooklyn Center" on Justia Law

In May 2017, Jorge Rivera-Guadalupe was living in a rooming house in Harrisburg, Pennsylvania. After being mugged, his friend Christopher Valkosak stayed with him. The next night, Valkosak was shot by a man in a black hoodie. Detective Jacob Pierce investigated and obtained a search warrant for Rivera-Guadalupe’s room, finding marijuana and other items but no gun. Rivera-Guadalupe was arrested and charged with multiple offenses, including attempted homicide. At trial, the prosecution dropped some charges, and Rivera-Guadalupe was acquitted of the remaining charges after being incarcerated for over eighteen months.The Middle District of Pennsylvania dismissed claims against other defendants but allowed the malicious prosecution claim against Det. Pierce to proceed. Det. Pierce sought dismissal based on qualified immunity, arguing that probable cause for one charge should shield him from liability for malicious prosecution on other charges. The District Court, referencing Johnson v. Knorr, denied qualified immunity, distinguishing it from Wright v. City of Philadelphia, which applied the "any-crime" rule to false arrest claims.The United States Court of Appeals for the Third Circuit reviewed the case. The court concluded that the right to be prosecuted only on charges supported by probable cause was not clearly established in 2017 due to conflicting precedents in Wright and Johnson. The court noted that the Supreme Court's recent decision in Chiaverini v. City of Napoleon clarified that probable cause for one charge does not defeat a malicious prosecution claim for other charges lacking probable cause. However, this was not clearly established law at the time of Rivera-Guadalupe’s arrest. Therefore, the Third Circuit reversed the District Court’s denial of qualified immunity for Det. Pierce and remanded the case for dismissal on that basis. View "Jorge Rivera-Guadalupe v. City of Harrisburg" on Justia Law

Steven Catlin, a California state prisoner, appealed the district court’s denial of his 28 U.S.C. § 2254 habeas corpus petition challenging his 1990 conviction for the murders of his fourth wife, Joyce Catlin, and his adoptive mother, Martha Catlin, as well as his death sentence. Catlin was convicted of murdering three family members with paraquat, a poisonous herbicide. The habeas petition in this case relates to his convictions for the murders of Joyce and Martha and the death sentence for Martha’s murder.The California Supreme Court (CSC) summarily denied Catlin’s first state habeas petition on the merits in 2007 and rejected his second state habeas petition in 2013 as procedurally barred. The district court denied Catlin’s federal habeas petition and his motion for discovery and evidentiary development in 2019, granting a certificate of appealability on several claims.The United States Court of Appeals for the Ninth Circuit reviewed Catlin’s claims under the deferential standard set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA). The court affirmed the district court’s denial of Catlin’s habeas petition, concluding that the CSC reasonably rejected Catlin’s claims. The court held that the CSC acted reasonably in rejecting Catlin’s claims of error arising from the state trial judge’s ex parte discussion with a juror, concluding that there was no ineffective assistance of counsel at both the guilt and penalty phases of Catlin’s trial, and determining that there was no violation of due process rights under Brady v. Maryland and Napue v. Illinois.The Ninth Circuit also declined to issue a certificate of appealability for Catlin’s uncertified claim that the state violated his due process rights by withholding exculpatory evidence and presenting false evidence. The court found that no reasonable jurist could debate the district court’s resolution of this claim. View "CATLIN V. BROOMFIELD" on Justia Law

The case involves Lori Ann Wiley, who, along with Charles Wallace Hanson, engaged in a verbal altercation at a Kern High School District (KHSD) high school. The incident began when a school employee blocked a handicap parking spot they intended to use. Wiley later submitted a written complaint about the incident to the school. Subsequently, KHSD police officer Michael Whiting recommended various misdemeanor charges against Wiley, leading to her being cited and a prosecutor filing a criminal complaint with three misdemeanor charges. After a mistrial, the court dismissed Wiley’s charges in the interest of justice.Wiley sued KHSD police officers Edward Komin, Michael Whiting, Luis Peña, and Steven Alvidrez, alleging violations of her First Amendment rights, malicious prosecution, and abuse of process. She brought causes of action under 42 U.S.C. section 1983, the Bane Act, and common law torts for intentional infliction of emotional distress and negligence. The trial court sustained the defendants’ demurrer to Wiley’s causes of action in the second amended complaint on multiple grounds without leave to amend and granted a motion to strike Wiley’s punitive damages allegations without leave to amend.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court affirmed the trial court’s decision in part and reversed it in part. The appellate court held that Wiley failed to adequately plead her claims under section 1983 for malicious/retaliatory prosecution and abuse of process, as well as her claims under the Bane Act. The court also found that the defendants were entitled to qualified immunity and that Wiley did not sufficiently allege facts to support her claims for intentional infliction of emotional distress and negligence. However, the court granted Wiley leave to amend her section 1983 claim but denied leave to amend her other causes of action. The court affirmed the trial court’s order granting the motion to strike without leave to amend. View "Wiley v. Kern High School District" on Justia Law

The appellant, Shawn Lee Perrot, was convicted in 2004 of multiple sexual offenses involving minors, including forcible rape, lewd acts on a child, and distribution of lewd material to a minor. After serving over 16 years of a 21-year sentence, he was paroled with specific conditions. Perrot violated three parole conditions: accessing and using computer devices, associating with known sex offenders, and possessing sexually stimulating devices. He challenged these conditions as unconstitutionally vague and overbroad.Upon his release, Perrot refused to sign parole conditions, leading to civil commitment proceedings, which were later dismissed. He was evaluated as high risk for reoffending. Perrot signed parole conditions, including prohibitions on computer access, associating with sex offenders, and possessing sexually stimulating devices. He filed grievances and a habeas corpus petition challenging these conditions, which were largely denied, though he was temporarily allowed limited computer use for legal research.The Department of Adult Parole Operations filed a petition for parole revocation, alleging Perrot violated the conditions. Evidence showed he possessed multiple unauthorized devices, operated a business assisting sex offenders, and had sexually stimulating devices. The court found probable cause and revoked his parole, sentencing him to a 60-day jail term, followed by reinstatement to parole.The California Court of Appeal, First Appellate District, reviewed the case. The court rejected Perrot's claims, holding that the parole conditions were not unconstitutionally vague or overbroad. The court found the conditions were sufficiently precise and narrowly tailored to address the state's compelling interest in preventing Perrot from reoffending. The order revoking Perrot's parole was affirmed. View "P. v. Perrot" on Justia Law

Nathaniel Pryor was stopped by police in Aurora, Illinois, after officers received a tip about drug activity linked to a van. Pryor exited the van quickly, and an officer ordered him to the ground, took him down, struck him twice, and searched him. No drugs were found, and Pryor was charged with obstructing/resisting a police officer, but the charge was later dropped. Pryor then sued several officers and the City of Aurora, alleging multiple federal and state law claims, including under 42 U.S.C. § 1983.The United States District Court for the Northern District of Illinois granted in part the defendants' motion for summary judgment, dismissing some claims and allowing others to proceed to trial. At trial, the jury found in favor of the defendants on the remaining claims. Pryor appealed, arguing that the district court erred in its summary judgment decision and in various evidentiary and procedural rulings during the trial.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment on Pryor’s false arrest claim, finding that the officers had probable cause to arrest him for obstruction of justice and resisting arrest. The court also upheld the district court’s decision to grant qualified immunity to the officer for the leg sweep and tackle, as Pryor failed to show that the use of force was clearly established as excessive under the circumstances. Additionally, the court found that the searches conducted by the officer were proper incidents to Pryor’s arrest and were not extreme or patently abusive.The Seventh Circuit also affirmed the district court’s evidentiary and procedural rulings, including the admission of drug surveillance evidence, the exclusion of certain testimony by Pryor, and the handling of jury instructions. The court concluded that the district court did not abuse its discretion in these decisions and that any errors were harmless. The judgment of the district court was affirmed in full. View "Pryor v. Corrigan" on Justia Law

Jessie Grace was convicted of second-degree murder in 1994 and sentenced to life in prison without the possibility of probation or parole. The Louisiana Fifth Circuit affirmed his conviction. Over the next 18 years, Grace filed several post-conviction relief applications, all of which were denied until 2012, when he was granted leave to reopen his federal proceedings based on newly discovered evidence. Grace obtained state grand jury testimony that revealed discrepancies between the grand jury and trial testimonies of two key witnesses: Sergeant Snow and Michelle Temple. These discrepancies suggested that another individual, Darrick Hudson, might have been involved in the crime.In 2015, Grace filed a third application for post-conviction relief in state trial court, alleging Brady violations based on the grand jury testimony. The state trial court granted his application, vacated his conviction, and ordered a new trial. The State appealed, and the Louisiana Fifth Circuit reversed the trial court's decision, reinstating Grace's life sentence. The Louisiana Supreme Court denied Grace's subsequent writ application in 2019. Grace then filed a second supplemental application in federal district court, asserting a Brady claim. The district court granted relief, but the United States Court of Appeals for the Fifth Circuit vacated the order and remanded for further proceedings.On remand, the district court again granted Grace's habeas relief, finding that the state court erred in its consideration of the materiality of the suppressed evidence. The State appealed, and the Fifth Circuit reviewed the case. The Fifth Circuit determined that the state court's decision was not an unreasonable application of clearly established federal law and that the suppressed evidence was not material enough to undermine confidence in the verdict. The Fifth Circuit reversed the district court's decision and denied Grace's application for habeas relief. View "Grace v. Hooper" on Justia Law