Justia Civil Rights Opinion Summaries

A prisoner in the Illinois Department of Corrections was issued two disciplinary tickets for alleged gang affiliation after a gang-related questionnaire, purportedly filled out by him, was found in another inmate’s belongings. The first ticket was dismissed after a hearing, but a second, nearly identical ticket was issued shortly thereafter, leading to his immediate placement in segregation. The second ticket included additional allegations, such as handwriting analysis and claims of self-admitted gang membership. The prisoner remained in segregation for three months under conditions he described as inhumane, including exposure to mold, mildew, insects, rust, and leaking sewage. He filed grievances challenging the process and the conditions, and the ticket was eventually expunged for failure to follow internal procedures, but only after he had served the segregation term.The United States District Court for the Southern District of Illinois granted summary judgment to the defendants, holding that even if there were factual disputes about whether the prisoner was denied witnesses, he had not demonstrated that the conditions of segregation constituted an “atypical and significant hardship” sufficient to implicate a protected liberty interest under the Due Process Clause.On appeal, the United States Court of Appeals for the Seventh Circuit assumed, without deciding, that the prisoner’s conditions in segregation established a liberty interest. However, the court held that, under its recent precedent in Adams v. Reagle, prisoners who do not face the loss of good-time credits or other sentence-lengthening punishments are entitled only to informal, nonadversarial due process. The court found that the prisoner received the required process: notice of the charges, an opportunity to respond, and an impartial decisionmaker. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "Torres v Brookman" on Justia Law

Six women who were formerly incarcerated at the Jasper City Jail in Alabama alleged that they suffered repeated sexual abuse by jailers, primarily by one officer, while serving as inmates. The plaintiffs described a range of sexual assaults and harassment, with one plaintiff also alleging abuse by a second jailer. The jail operated under the authority of the City of Jasper’s police chief, with a chief jailer and other supervisory staff responsible for daily operations. Jail policies expressly prohibited sexual contact between staff and inmates, and there were procedures for reporting grievances, but the plaintiffs claimed these mechanisms were ineffective or inaccessible.After the alleged abuse, the Alabama State Bureau of Investigation began an inquiry, leading to the resignation of the primary alleged abuser and, later, his indictment on state charges. The plaintiffs filed six separate lawsuits, later consolidated, asserting claims under 42 U.S.C. § 1983 for Eighth Amendment violations against the police chief, chief jailer, and the City, as well as claims under the Trafficking Victims Protection Reauthorization Act (TVPRA). One plaintiff also brought claims against a second jailer. The United States District Court for the Northern District of Alabama granted summary judgment to all defendants, finding insufficient evidence that the supervisory officials or the City had knowledge of, or were deliberately indifferent to, the alleged abuse, and that the claims against one jailer failed for lack of proper service.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs failed to establish a causal link between the actions or inactions of the supervisory officials or the City and the alleged constitutional violations, as there was no evidence of a widespread custom or policy of tolerating sexual abuse, nor of deliberate indifference or failure to train. The court also found that certain claims were time-barred and that the TVPRA claims failed due to lack of evidence that the City knowingly benefited from or had knowledge of the alleged trafficking. View "Bridges v. Poe" on Justia Law

A Black man was charged with multiple offenses, including felony false imprisonment, after a domestic violence incident in which his girlfriend alleged he struck her and prevented her from leaving his car. Witnesses observed the girlfriend attempting to exit the moving vehicle and heard shouting. The girlfriend initially told police that the defendant hit her and threatened her if she tried to leave, but later recanted, claiming she fabricated the story out of anger. The prosecution introduced both her initial statements and her recantation at trial. The jury found the defendant guilty of felony false imprisonment and other related charges, but acquitted him of attempted robbery. He admitted a prior conviction, and the trial court imposed a total sentence of nine years and four months, including time for an unrelated prior case.During trial, the defendant’s counsel raised concerns under the California Racial Justice Act (RJA) regarding the racial composition of the jury venire and the prosecution’s peremptory challenge of a Black prospective juror. The Santa Clara County Superior Court denied these motions, finding no evidence of bias or violation of the RJA. At sentencing, the court made comments referencing the defendant’s race and background, but defense counsel did not object to these statements under the RJA.The California Court of Appeal, Sixth Appellate District, reviewed the case. It held that the defendant forfeited his RJA claims on appeal by failing to object to the trial court’s statements at the appropriate time. The court also found no merit in the claim of ineffective assistance of counsel, as there was a conceivable tactical reason for not objecting. Additionally, the appellate court determined that the trial court did not err in failing to instruct the jury on misdemeanor false imprisonment, as there was no substantial evidence to support that lesser offense. The judgment of conviction and sentence was affirmed. View "People v. Wagstaff" on Justia Law

An individual was admitted to a hospital after a medical emergency and, following treatment, was held for mental health concerns. Hospital staff petitioned for his transport to a designated evaluation facility, citing symptoms of serious mental illness and inability to make rational decisions. Although the court ordered immediate transport for evaluation, the individual remained at the hospital for two weeks due to lack of capacity at evaluation facilities. After a hearing, the court found this prolonged detention violated his substantive due process rights and ordered his release. However, the individual remained at the hospital for three more days, after which the hospital filed a second petition based on new information. The court granted this petition, and the individual was detained for an additional nine days before being transported for evaluation.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, first dismissed the initial petition and ordered the individual's release, finding the extended detention unconstitutional. Upon the hospital’s second petition, the court approved another period of detention, reasoning that new information justified the renewed hold and that delays were due to facility refusals and capacity issues. After the individual was finally transported and evaluated, the evaluation facility petitioned for a 30-day commitment, which the superior court granted following a hearing.The Supreme Court of the State of Alaska reviewed the case. It held that the second period of detention, especially when considered alongside the prior extended detention, violated the individual’s substantive due process rights because the nature and duration of the detention were not reasonably related to the limited purpose of facilitating immediate transportation for evaluation. The court also found that the State failed to prove by clear and convincing evidence that commitment was the least restrictive alternative. Accordingly, the Supreme Court vacated both the superior court’s order upholding the second detention and the 30-day commitment order. View "In the Matter of the Necessity for the Hospitalization of: Tavis J." on Justia Law

Early one morning, law enforcement officers went to the home of an individual whose son was suspected of assault and possibly being armed. The officers approached the house from different sides, announced their presence, and knocked on the front and side doors. The resident, believing his son was at the door, opened the back door—where no officer had knocked—and walked back inside without seeing or speaking to any officer. An officer then entered the home through the open back door without a warrant or exigent circumstances, only announcing his presence after passing through the kitchen. The resident, who was in his bedroom, was confronted, tased, handcuffed, and detained outside for a period of time.The resident filed suit in the United States District Court for the Northern District of Florida, alleging unlawful entry and unlawful seizure (including excessive force) in violation of the Fourth Amendment. After discovery, the officer moved for summary judgment on the basis of qualified immunity. The district court denied summary judgment on both the unlawful entry and unlawful seizure claims, finding that material factual disputes precluded qualified immunity. The officer appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, construing the facts in the light most favorable to the plaintiff, a reasonable jury could find that the officer entered the home without consent, in violation of clearly established Fourth Amendment law. The court affirmed the district court’s denial of summary judgment on the unlawful entry claim. However, the court found that the unlawful seizure and excessive force claims were entirely derivative of the unlawful entry claim, and therefore vacated the denial of summary judgment on those claims, remanding for the district court to treat them as subsumed within the unlawful entry claim. View "Dukes v. Gregory" on Justia Law

Two inmates in Virginia, each serving sentences for attempted aggravated murder, were initially informed by the Department of Corrections that they would be released in July 2022 due to a new state law expanding sentence credits for good behavior. This law, H.B. 5148, allowed certain inmates to earn more credits and thus reduce their incarceration time. However, after a change in the Attorney General’s office, the new Attorney General issued an advisory opinion stating that inmates convicted of inchoate offenses related to aggravated murder were not eligible for the enhanced credits. As a result, the Department reversed its earlier decision and kept the inmates incarcerated for an additional year, until the Supreme Court of Virginia later clarified that such inmates were indeed eligible for the credits and ordered their release.The inmates then filed a lawsuit in the United States District Court for the Eastern District of Virginia, seeking damages under 42 U.S.C. § 1983. They alleged that the Attorney General and the Director of Corrections violated their Eighth and Fourteenth Amendment rights by acting with deliberate indifference to their over-incarceration. The district court dismissed the complaint, finding that both officials had acted reasonably in interpreting an unsettled question of state law and that their conduct did not rise to the level of deliberate indifference or conscience-shocking behavior.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the officials’ actions did not constitute deliberate indifference under the Eighth Amendment, nor did they shock the conscience under the Fourteenth Amendment. The court emphasized that federal courts should not hold state officials personally liable for reasonable legal interpretations of unsettled state law, especially when those interpretations are made in good faith and with conventional legal reasoning. View "Swart v. Miyares" on Justia Law

A man was accused of sexually abusing a minor, referred to as Jane Doe, based on allegations that surfaced in 2018 and 2019. Initially, the police received a referral from Child Protective Services after Doe made statements to a suicide hotline about being abused by her “father’s friend.” The case was closed when Doe refused to discuss the allegations. In 2019, after another suicide attempt, Doe identified the man by name during therapy, and this information was relayed to the police. Detective Thorsdottir conducted a forensic interview with Doe, who provided detailed accounts of abuse and identified the accused. The investigation included interviews with Doe’s parents and therapists, surveillance, and searches of the accused’s home, which yielded a handgun but no evidence of child pornography. The accused was arrested and indicted, but the charges were later dropped after new evidence suggested Doe had previously identified a different individual as her abuser.The accused filed a civil suit in Virginia state court, later removed to the United States District Court for the Eastern District of Virginia, alleging malicious prosecution under both state law and the Fourth Amendment. The district court dismissed the complaint under Rule 12(b)(6), finding that the plaintiff failed to plausibly allege a lack of probable cause for his arrest and prosecution, and that the detective was entitled to qualified immunity on the federal claim.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissal de novo. The court held that the complaint and its exhibits did not plausibly allege that the detective acted with deliberate or reckless disregard for the truth, nor that she omitted material facts necessary to negate probable cause. The court concluded that probable cause existed based on Doe’s identification and corroborating evidence, and affirmed the district court’s dismissal of both the federal and state malicious prosecution claims. View "Moretti v. Thorsdottir" on Justia Law

Shawn Otis Hernandez was convicted by a jury of conspiracy to commit first degree residential burglary and attempted first degree residential burglary, following an incident in which multiple individuals attempted to break into a home late at night. Evidence against Hernandez included cell phone records, home security video, DNA analysis, and a prior conviction for a similar crime. During jury selection, the prosecution exercised several peremptory challenges against jurors under the age of 25, prompting Hernandez to object on the basis that these challenges were discriminatory.The Ventura County Superior Court reviewed Hernandez’s objection under Code of Civil Procedure section 231.7, which prohibits discrimination in jury selection based on certain protected categories. The trial court found that the prosecution’s reasons for excusing the young jurors were valid and supported by the record, and that age was not a substantial factor in the use of peremptory challenges. The court also noted that neither party raised objections based on ethnicity or gender during trial, and that the empaneled jury included several males and individuals with Spanish surnames.The California Court of Appeal, Second Appellate District, Division Six, affirmed the judgment. The court held that youth alone is not a cognizable group under section 231.7, and neither Batson v. Kentucky nor Wheeler prohibits excusing jurors solely based on youth. The court further held that objections to the dismissal of jurors based on protected class membership under section 231.7 must be made in the trial court, or the claim is forfeited on appeal. Hernandez’s claims regarding ethnicity and gender were deemed forfeited, and his ineffective assistance of counsel claim was rejected due to lack of deficient performance and prejudice. The judgment was affirmed. View "People v. Hernandez" on Justia Law

A city commissioner in Coffee County, Georgia, who was active in assisting voters, became involved in a heated exchange with the county’s Elections Supervisor at a polling site during early voting for the 2020 general election. After the confrontation, the police were called, and the commissioner left. Later that day, she returned to the polling site to assist another voter, prompting another police response. A City of Douglas police sergeant then issued her a criminal trespass warning, banning her from all county polling places for the remainder of the election period. When she refused to leave, she was arrested.The commissioner filed a lawsuit in the United States District Court for the Southern District of Georgia against the Elections Supervisor and Coffee County, alleging that the trespass warning violated her First Amendment rights and that her arrest violated the Fourth Amendment. The district court granted summary judgment to the defendants, finding that the police sergeant, not the Elections Supervisor or the County, had issued the trespass warning and made the arrest. The court concluded that the plaintiff failed to show that the defendants caused her alleged injuries, as required under 42 U.S.C. § 1983.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that the plaintiff did not present sufficient evidence for a reasonable jury to conclude that the Elections Supervisor, rather than the police sergeant, caused her injuries. The court explained that the sergeant acted as a deliberative and autonomous decision-maker, conducting his own investigation and independently deciding to issue the trespass warning and make the arrest. Because causation is a necessary element of a § 1983 claim, and the plaintiff failed to establish it, summary judgment for the defendants was affirmed. View "Coley-Pearson v. Martin" on Justia Law

Five University of Kentucky football players attended a fraternity party where they were subjected to racial slurs and, in some cases, physical assault by attendees. After the incident, a fraternity member called the police and accused the players of assault and burglary, claiming they brandished weapons. Detective Cory Vinlove led the investigation and, despite evidence suggesting the players were victims, allegedly fabricated information to support criminal charges against them. The university cleared the players of wrongdoing, but Vinlove proceeded with charges, and a police press release publicized the allegations. Ultimately, a grand jury declined to indict the players, but the negative publicity had already damaged their reputations and careers.The players filed lawsuits in the United States District Court for the Eastern District of Kentucky against Vinlove, Sergeant Donnell Gordon, Police Chief Lawrence Weathers, and the Lexington-Fayette Urban County Government, asserting federal claims under 42 U.S.C. § 1983 (including malicious prosecution and fabrication of evidence) and various state-law claims. The district court consolidated the cases and granted the defendants’ motion to dismiss all claims except a state-law malicious prosecution claim against Vinlove. The court found that the plaintiffs had not alleged a deprivation of liberty under the Fourth Amendment, as required for their federal claims, and that the state-law claims were inadequately pled. The court later dismissed the remaining state-law claim for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the plaintiffs failed to allege a deprivation of liberty under the Fourth Amendment, as they were not arrested, detained, or subject to pretrial restrictions. The court also held that the press release was absolutely privileged under Kentucky law, defeating the defamation claim, and that the plaintiffs did not sufficiently allege that Gordon or Weathers initiated or continued the prosecution, defeating the state-law malicious prosecution claim. View "Adams v. Lexington-Fayette Urban County Gov't" on Justia Law