Justia Civil Rights Opinion Summaries

Gabino Ramos Hernandez was involved in a traffic stop on July 20, 2016, where he was stopped by Laurel Police Department Officer David Driskell for failing to stop at a stop sign. Hernandez's brother, who appeared intoxicated, was also stopped. Officer Driskell called Immigration and Customs Enforcement (ICE) agents for translation assistance. Hernandez, who was initially waiting, decided to leave the scene and was pursued by ICE agents. During the pursuit, ICE Agent Phillip Causey shot Hernandez, who alleges he had his hands raised in surrender.Hernandez filed a lawsuit against Causey under 42 U.S.C. § 1983 and Bivens, along with other claims. The United States District Court for the Southern District of Mississippi dismissed the Bivens claim, stating it would expand Bivens to a new context, and dismissed the § 1983 claim, finding Causey did not act under color of state law. The court also denied Hernandez's motion to amend the complaint, deeming further amendment futile.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's dismissal of the Bivens claim, agreeing that Hernandez's claim presented a new context and that alternative remedies existed. The court also affirmed the dismissal of the § 1983 claim, concluding that Hernandez failed to allege that Causey acted under color of state law or that there was a conspiracy between Causey and state officials. The court upheld the denial of Hernandez's motion to amend the complaint, as further amendment would be futile. View "Hernandez v. Causey" on Justia Law

Carl Grant, a Vietnam War veteran suffering from dementia and PTSD, left his home in Conyers, Georgia, on February 2, 2020, and ended up in Birmingham, Alabama. Officer Vincent Larry of the Birmingham Police Department found Grant disoriented and detained him for a misdemeanor. Grant was taken to a hospital, where he was treated for minor injuries. While being escorted to the restroom, Larry allegedly assaulted Grant, causing severe spinal injuries that led to Grant's death on July 24, 2020. William Jenkins, representing Grant's estate, filed a lawsuit against Larry, the City of Birmingham, and various city officials.The Jefferson Circuit Court granted a summary judgment in favor of the City defendants, dismissing Jenkins's claims with prejudice on February 22, 2023. Jenkins filed a postjudgment motion on March 21, 2023, which was denied by operation of law on June 20, 2023. Jenkins also filed a "motion for clarification" on April 28, 2023, which the court purported to grant on June 21, 2023, reinstating claims against Larry and Scott Thurmond. However, this order was a nullity as the court had lost jurisdiction after the postjudgment motion was denied by operation of law.Jenkins filed a notice of appeal on November 3, 2023, which was dismissed as arising from a non-final order. He then filed another appeal on January 24, 2024, which was transferred to the Supreme Court of Alabama. The Supreme Court of Alabama dismissed the appeal, instructing the circuit court to vacate its June 21, 2023, order and all subsequent orders, as they were nullities. The February 22, 2023, judgment was deemed final, and Jenkins's failure to appeal it timely resulted in the dismissal of his current appeal. View "Jenkins v. City of Birmingham" on Justia Law

Artell Young, a federal supervised releasee, was subject to a search condition allowing federal probation officers to search his person, vehicle, or home upon reasonable suspicion of contraband or release condition violations. After receiving information that Young was dealing drugs and possessing a firearm, federal probation officers searched his home, finding small amounts of crack cocaine, powdered cocaine, and marijuana. The federal authorities turned the case over to Iowa authorities, leading to Young's conviction on several drug offenses.In the Iowa District Court for Polk County, Young moved to suppress the evidence from the search, arguing it violated the Fourth Amendment and article I, section 8 of the Iowa Constitution. The district court upheld the search, citing the "special needs" exception under both the Fourth Amendment and article I, section 8. The court also noted that the search was conducted by federal officers under federal standards, thus not subject to Iowa constitutional standards. Young was convicted by a jury of three counts of possession of a controlled substance and sentenced to six years in prison.The Iowa Supreme Court reviewed the case, focusing on whether the search violated article I, section 8 of the Iowa Constitution. The court held that the constitutionality of the search should be evaluated by the law of the sovereign that conducted the search—in this case, federal law. The court affirmed the district court's decision, concluding that the search was lawful under federal standards and that the evidence obtained was admissible in the state prosecution. The court rejected Young's claim of an illegal search and affirmed his convictions. View "State of Iowa v. Young" on Justia Law

A man named Johnathon Lerke, who was under a Murphy conservatorship, challenged his confinement in a county jail while awaiting transfer to a state hospital. Murphy conservatorships are for individuals found incompetent to stand trial and deemed a danger to others. Despite being ordered to a state hospital, Lerke was held in county jail for months due to a lack of space at the hospital. He argued that his confinement in jail was unauthorized and violated his rights.The Superior Court initially found Lerke incompetent to stand trial and ordered him to a state hospital for competency restoration. After nearly two years, the hospital reported that Lerke had not regained competence. Subsequently, a Murphy conservatorship was established, requiring his placement in a state hospital. However, due to the unavailability of space, he remained in county jail. Lerke's counsel requested his release or transfer to a local psychiatric hospital, but the court denied the request, stating that he would remain in jail until a state hospital bed became available.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court concluded that no legal authority permitted Lerke’s indefinite detention in county jail pending his transfer to the state hospital. The statutory framework requires conservatees to be placed in treatment facilities that promote their treatment and protect the public, and county jails do not meet these requirements. Although the court found Lerke’s confinement in jail unlawful, it denied habeas relief because he had already been transferred to an authorized treatment facility during the proceedings. The petition for writ of habeas corpus was denied as moot. View "In re Lerke" on Justia Law

Nathan Wilson and Christopher Beasley were alleged to have set fire to a police car during a protest in Santa Monica, California, following the killing of George Floyd. They were federally indicted on one count of arson. The defendants moved to dismiss the indictment, arguing they were selectively prosecuted based on perceived anti-government views. Alternatively, they sought discovery on their selective-prosecution claim.The United States District Court for the Central District of California denied the motion to dismiss but granted discovery on the selective-prosecution claim. The government indicated it would seek appellate review rather than comply with the discovery order, leading the district court to dismiss the indictment without prejudice.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that it had jurisdiction under 18 U.S.C. § 3731, which allows for government appeals in criminal cases without requiring final decisions. The court found that the district court abused its discretion by granting discovery based on an erroneous view of the law. The district court had incorrectly defined the control group for determining discriminatory effect, failing to account for relevant factors beyond committing the same crime in the same location.The Ninth Circuit reversed the district court’s selective-prosecution discovery order and the dismissal of the indictment without prejudice. The case was remanded for further proceedings consistent with the opinion. The court did not address whether the defendants presented evidence of discriminatory intent. View "USA V. WILSON" on Justia Law

In this case, two organizations and four individuals brought an action under 42 U.S.C. § 1983 against the City of Phoenix and several police officers, alleging violations of their constitutional rights during a protest outside a rally held by then-President Trump at the Phoenix Convention Center on August 22, 2017. The plaintiffs claimed that the police used excessive force and violated their First, Fourth, and Fourteenth Amendment rights by dispersing the protesters with tear gas, chemical irritants, and flash-bang grenades.The United States District Court for the District of Arizona certified two classes and granted summary judgment to the defendants on all claims except for the individual Fourth Amendment excessive-force claims asserted by three plaintiffs against certain officers. The court found that there was no "seizure" of the class members under the Fourth Amendment and evaluated the excessive-force claims under the Fourteenth Amendment's "shocks-the-conscience" test. The court also granted summary judgment to the defendants on the First Amendment claims, finding no evidence of retaliatory intent.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's summary judgment for the defendants on the class claims. The Ninth Circuit agreed that the use of airborne and auditory irritants did not constitute a "seizure" under the Fourth Amendment and that the Fourteenth Amendment's "purpose to harm" standard applied. The court found no evidence of an improper purpose to harm by the officers.The Ninth Circuit reversed the district court's denial of summary judgment to the individual defendants on the excessive-force claims asserted by the three plaintiffs, holding that the officers were entitled to qualified immunity. The court found that the officers acted reasonably under the circumstances or did not violate clearly established law. The court also affirmed the district court's summary judgment for the individual defendants on the First Amendment claims, finding that the officers had objectively reasonable grounds to disperse the crowd due to a clear and present danger.Finally, the Ninth Circuit affirmed the district court's summary judgment for Police Chief Williams and the City of Phoenix, concluding that there was no evidence that Williams caused or ratified the use of excessive force or that the City was deliberately indifferent to the plaintiffs' constitutional rights. View "PUENTE V. CITY OF PHOENIX" on Justia Law

The defendant, Angelo Clark, was charged with multiple counts of attempted first-degree murder and aggravated battery following a gang-related shooting in 2013 that injured two people. Clark moved to quash his arrest, which was based on an investigative alert issued by the Chicago Police Department. The circuit court denied his motion, and Clark did not contest this denial further in the circuit court.In 2017, a jury in the Cook County Circuit Court convicted Clark of two counts of aggravated battery with a firearm under an accountability theory. He was initially sentenced to 46 years in prison, which was later reduced to 32 years upon reconsideration.Clark appealed, and the Appellate Court, First District, affirmed his conviction and sentence. The appellate court rejected Clark's argument that his arrest was unconstitutional because it was based on an investigative alert rather than a warrant. The court also found no plain error in the circuit court's consideration of sentencing factors for juvenile offenders, as Clark was 17 at the time of the offense.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's judgment. The court held that warrantless arrests based on probable cause do not violate the Illinois Constitution, even if communicated via an investigative alert. The court also found that the circuit court had considered the relevant factors for sentencing juvenile offenders, as required by section 5-4.5-105(a) of the Unified Code of Corrections, and thus, there was no clear or obvious error in the sentencing process. View "People v. Clark" on Justia Law

David Vincent was stopped by Officer David Robertson of the Edmonton Police Department based on a tip from a known informant and an alleged equipment violation. The informant reported that two individuals at a gas station appeared to be intoxicated. Officer Robertson observed a vehicle with red parking lights, which he believed violated a new law that had not yet taken effect. He followed the vehicle, observed no traffic violations, and stopped it. Vincent was found to have a suspended license, and a search of the vehicle revealed drugs and paraphernalia.The Metcalfe Circuit Court denied Vincent's motion to suppress the evidence obtained from the stop, ruling that the officer's belief about the equipment violation was an objectively reasonable mistake of law. The court also found the informant's tip provided a sufficient basis for the stop. Vincent entered a conditional guilty plea, reserving the right to appeal the suppression ruling. The Court of Appeals affirmed the trial court's decision, holding that the stop was supported by reasonable suspicion and the subsequent search was lawful under the automobile exception to the warrant requirement.The Supreme Court of Kentucky reviewed the case and reversed the lower courts' decisions. The court held that the stop was not justified by the equipment violation because the law had not yet taken effect, and the officer's mistake of law was not reasonable. Additionally, the informant's tip did not provide reasonable suspicion for the stop, as it was based on observations that could be explained by innocent behavior and was not corroborated by the officer's own observations. The court remanded the case for the trial court to grant Vincent's motion to suppress the evidence obtained from the unlawful stop. View "VINCENT V. COMMONWEALTH OF KENTUCKY" on Justia Law

Officer Henry Volentine, a deputy of the Hardin County Office of Sheriff (HCOS), initiated a traffic stop of Maurice Green on October 14, 2014, after noticing Green's vehicle had an expired license plate belonging to a different vehicle. Green initially pulled over but then drove off, prompting Volentine to pursue him. During the pursuit, Volentine believed Green had committed assault and wanton endangerment by nearly hitting two pedestrians. The pursuit ended in a head-on collision with Susan Sheehy’s vehicle, leading to the present litigation.The Hardin Circuit Court denied Volentine’s and HCOS’ motion for summary judgment based on qualified and governmental immunity. The court found that Volentine did not have a reasonable basis to believe a violent felony had occurred to justify the pursuit and that his actions were not in good faith. The court also determined that Volentine violated ministerial duties by failing to terminate the pursuit when it posed an extreme safety hazard and by not obtaining approval from a supervisor to continue the pursuit.The Kentucky Court of Appeals reversed the trial court’s decision, holding that Volentine was entitled to qualified official immunity and that HCOS was entitled to governmental immunity. The Court of Appeals reasoned that Volentine’s belief that he witnessed a felony was reasonable and that his actions during the pursuit were discretionary.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals. The Supreme Court held that Volentine was not entitled to qualified official immunity because he failed to abide by ministerial duties and lacked good faith in exercising his discretion to initiate the pursuit. Consequently, HCOS’ governmental immunity was waived by operation of KRS 70.040. The case was remanded to the Hardin Circuit Court for further proceedings consistent with the Supreme Court’s opinion. View "SHEEHY V. VOLENTINE" on Justia Law

Tyler Story was charged with first-offense DUI after being observed driving at high speed with one headlight and failing field sobriety tests. He admitted to drinking and had a breathalyzer result of 0.178. Story requested an independent blood test, which was drawn but not tested immediately. The sample was stored by the police. Story was charged and sought to preserve the sample for independent testing. The District Court suppressed the breathalyzer results due to an error in administration, leaving the Commonwealth without evidence. The Commonwealth obtained a warrant to test the independent blood sample, which Story opposed.The Campbell District Court denied Story's motion to return the blood sample for independent testing, finding he had abandoned it. The Campbell Circuit Court denied Story's petition for a writ of prohibition against the search warrant. The District Court allowed the Commonwealth to test the sample, which showed a blood alcohol level above the legal limit. Story entered a conditional guilty plea and appealed. The Circuit Court and the Court of Appeals affirmed the District Court's decisions, with the Court of Appeals disagreeing on the abandonment but upholding the testing as evidence.The Supreme Court of Kentucky reviewed the case and found that Story's statutory right to an independent blood test was infringed, but the error was harmless since the breathalyzer test was suppressed. However, the Court concluded that the Commonwealth's testing of the blood sample was conducted under an invalid warrant and without Story's consent, violating his Fourth Amendment rights. The Court reversed the District Court's denial of Story's motion to suppress the test results, vacated his conviction, and remanded for further proceedings. View "STORY V. COMMONWEALTH OF KENTUCKY" on Justia Law