Justia Civil Rights Opinion Summaries

In the case of the State of North Carolina v. Russell William Tucker, the defendant argued that his conviction for first-degree murder and sentence of death should be overturned due to alleged discrimination in jury selection. He asserted that newly discovered evidence, a continuing legal education handout and a statistical study, supported his claim of purposeful discrimination. However, the defendant had failed to raise a Batson claim (a claim of discrimination in jury selection) during his original trial or in previous post-conviction proceedings. The Supreme Court of North Carolina found that the defendant’s claim was procedurally barred and affirmed the judgment of the Superior Court.The defendant killed a security guard and shot two police officers in 1994. He was convicted of first-degree murder and sentenced to death. During jury selection, the defendant raised objections to the State’s peremptory strikes against black prospective jurors. The trial court found that the defendant failed to establish a prima facie case of purposeful discrimination, and the defendant did not raise a Batson claim on direct appeal or in previous post-conviction proceedings.In this appeal, the defendant argued that the handout and study constituted newly discovered evidence that would support a Batson claim. The defense argued that these materials showed a pattern of racial discrimination in jury selection in North Carolina. However, the Court held that the defendant's claim was procedurally barred because he could have raised a Batson claim during his original trial or in previous post-conviction proceedings but failed to do so. The Court also found that the handout and study did not constitute newly discovered evidence and did not show that the defendant was prejudiced by the alleged discrimination. Therefore, the Court concluded that the defendant’s Batson claim was procedurally barred and affirmed the judgment of the Superior Court. View "State v. Tucker" on Justia Law

In this case, the Plaintiff, Paul Steven Wynn, had sued Rex Frederick, in his official capacity as a magistrate, and Great American Insurance Company for negligence. The Plaintiff claimed that Frederick was negligent in sending a custody order to UNC Hospitals, instead of the Sheriff's Office, resulting in a delay in the involuntary commitment of the Plaintiff's nephew, who subsequently assaulted and paralyzed the Plaintiff.The Supreme Court of North Carolina held that magistrates, as state officials, are not included in the phrase "other officers" under North Carolina General Statute § 58-76-5, which speaks to the waiving of sovereign immunity for certain officials covered by a statutory bond. The court came to this conclusion by examining the structure and history of the statute, which revealed that the statute only encompasses county officers and not state officers. As such, the court found that the statute does not waive the magistrate's sovereign immunity.Furthermore, the court held that judicial immunity applies to both official and individual capacity claims, contrary to the ruling of the Court of Appeals, which had limited the defense of judicial immunity to individual capacity claims only. The court, however, did not decide whether the magistrate's conduct in this case constituted a judicial act, as it found that the claim was independently barred by sovereign immunity. The decision of the Court of Appeals was therefore reversed. View "Wynn v. Frederick" on Justia Law

In this case, an unincorporated association, Saline Parents, and six individuals sued the Attorney General of the United States, Merrick Garland, alleging that the Department of Justice (DOJ) was unlawfully attempting to silence them and others who opposed progressive curricula and policies in public schools. This lawsuit was in response to a memorandum issued by the Attorney General, expressing concern over the increase in reported incidents of harassment, intimidation, and threats of violence against school administrators, board members, teachers, and staff. The memorandum instructed the DOJ staff to investigate the issue and discuss strategies to address it. The plaintiffs argued that their protest activities, which included constitutionally protected conduct and did not involve threats of criminal violence, had been unfairly targeted by the DOJ.The United States Court of Appeals for the District of Columbia Circuit upheld the dismissal of the case by the District Court on the grounds that the plaintiffs lacked standing to pursue this action. The court agreed with the government's argument that the plaintiffs' lawsuit was not ripe for adjudication, indicating that the plaintiffs' claims were based on hypothetical future events that may not occur. The court also found that the plaintiffs had failed to demonstrate that the government had in any way threatened imminent enforcement action against them or had labeled them in a way that impugned their reputations. The court concluded that the plaintiffs' claim was based on contingencies and speculation, making the dispute premature for judicial resolution. View "Saline Parents v. Garland" on Justia Law

The United States Court of Appeals for the Second Circuit ruled that a group of non-transgender female athletes have legal standing to challenge a policy that allows transgender girls to compete in girls' high school sports. The athletes had sued the Connecticut Association of Schools and several school districts, claiming that the policy violated Title IX by depriving them of equal athletic opportunity. The court held that the athletes had established Article III standing because they had plausibly stated a concrete, particularized, and actual injury in fact - the alleged denial of equal athletic opportunity and concomitant loss of publicly recognized titles and placements during track and field competitions in which they competed against and finished behind transgender athletes. The court also held that the injury was plausibly redressable by monetary damages and an injunction ordering defendants to alter certain athletic records. The court did not rule on the merits of the athletes' Title IX claim, instead remanding the case to the district court for consideration of whether the athletes have plausibly stated a claim under Title IX. View "Soule ex rel. Stanescu v. Connecticut Association of Schools, Inc." on Justia Law

In this case, the Nebraska Supreme Court affirmed a lower court's decision, finding that the Middle Republican Natural Resources District (NRD) violated the due process rights of two landowners, Merlin Brown and Uhrich & Brown Limited Partnership, by having the same attorneys act as both prosecutors and participants in the adjudicatory process of the case. The court held that such a combination of prosecutorial and adjudicatory functions in the same individuals posed an intolerably high risk of actual bias, thus, infringing on the landowners' right to a fair trial by an impartial tribunal. In this case, the NRD had accused the landowners of violating certain ground water management rules. The case was initially heard by the Board of Directors of the NRD, whose decision to impose penalties on the landowners was informed by the same attorneys who had prosecuted the case on behalf of the NRD. The landowners appealed the Board's decision under the Administrative Procedure Act (APA), leading to the district court's reversal. The NRD then appealed to the Nebraska Supreme Court, which upheld the lower court's ruling. View "Uhrich & Brown Ltd. Part. v. Middle Republican NRD" on Justia Law

In the case at hand, the plaintiff, a civilly committed sexually dangerous person, petitioned the Department of Correction (DOC) for medical parole due to his deteriorating health conditions. The DOC denied his petition based on their policy that civilly committed individuals are ineligible for medical parole under G. L. c. 127, § 119A. The plaintiff sought review of this denial, arguing that his due process rights had been violated. A Superior Court judge allowed his motion for judgment on the pleadings and ordered the DOC to conduct a hearing on the plaintiff's medical parole petition.However, the Supreme Judicial Court of Massachusetts reversed the judge's order. The court held that the medical parole statute applies only to committed offenders serving a criminal sentence, not to civilly committed sexually dangerous persons. It further held that sexually dangerous persons may seek release due to terminal illness or physical or mental incapacity under G. L. c. 123A, § 9, and denying them an additional avenue for relief by means of the medical parole statute does not offend substantive due process. The Court concluded that the plaintiff's due process rights were not violated by the DOC's policy that precludes civilly committed sexually dangerous persons from eligibility for medical parole. View "Murphy v. Commissioner of Correction" on Justia Law

In an appeal before the United States Court of Appeals for the Fifth Circuit, Erma Wilson sought to overturn the decision of the U.S. District Court for the Western District of Texas which dismissed her federal civil rights suit against Midland County, Texas, and individuals Ralph Petty and Albert Schorre. Wilson was convicted of cocaine possession 22 years prior and she maintained her innocence, claiming that the cocaine found was not hers. The case revolved around her claim that she was denied due process since the assistant district attorney in her case, Ralph Petty, was also moonlighting as a law clerk for the judge presiding over her trial. Wilson was sentenced to eight years of community supervision which derailed her dream of becoming a nurse.Upon review, the Fifth Circuit held that Wilson's claim is barred by the "favorable termination" rule from Heck v. Humphrey. The rule states that a convicted party cannot seek § 1983 damages for unconstitutional conviction or imprisonment without first showing that the conviction or sentence has been reversed on appeal or otherwise declared invalid. The court noted that Petty’s dual role indeed constituted a conflict of interest that violated Wilson's constitutional right to a fair trial. However, under the court's precedent, noncustodial plaintiffs, such as Wilson, must meet the favorable-termination requirement, even if it’s practically impossible for them to do so. The court found that it was bound by prior circuit precedent and could only affirm the lower court's decision. The court noted that only the en banc court or the United States Supreme Court could deliver a different result. The court affirmed the judgment of the lower court. View "Wilson v. Midland County" on Justia Law

Shiheem Amos appealed the denial of his motion to suppress a firearm, which was found after he was stopped by police officers who suspected him of being involved in a disturbance reported at a nearby location. Amos argued that he was seized without reasonable suspicion, and therefore the firearm should not have been admissible in court. The United States Court of Appeals for the Third Circuit held that Amos was not seized until after he attempted to flee from the police officers, and at that point, the officers had reasonable suspicion to seize him based on his attempt to flee. Thus, the firearm was admissible, and the motion to suppress was correctly denied.Amos also challenged his 62-month sentence, which included an enhancement for a previous state court conviction that was classified as a crime of violence under the United States Sentencing Guidelines. The court records did not specify which subsection of the Pennsylvania aggravated assault statute Amos had been convicted under, but the government argued that all possible subsections qualified as a crime of violence. However, the Third Circuit held that one of the subsections, which can be violated by a failure to act, does not meet the definition of a crime of violence because it does not require the use of violent force. Therefore, the court vacated Amos's sentence and remanded for resentencing without the crime of violence enhancement. View "USA v. Amos" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit examined an appeal by John Lee Ralston, who was charged with being a prohibited person in possession of a firearm after a search of his residence. The search was conducted under a warrant that was primarily issued based on criminal activity suspected of another person, Colton Varty, who was believed to be residing on the same piece of property but in a different residence. Ralston argued the warrant did not establish probable cause that evidence would be located inside his house.The district court had denied Ralston’s motion to suppress the evidence obtained from the search of his residence, ruling that even though the warrant lacked probable cause, the officers acted in good faith, relying on the Leon good-faith exception. On appeal, the Court of Appeals for the Eighth Circuit disagreed and reversed the district court's decision.The Court of Appeals held that the Leon good-faith exception did not apply in this case. The court found that the affidavit supporting the warrant was so lacking in evidence connecting Ralston and his residence to the suspected criminal activity of Varty that no reasonable officer would have relied upon a warrant that was issued based on it. The Court of Appeals concluded that without evidence that Varty had access to Ralston’s residence or facts pointing to a fair probability that Ralston’s residence contained stolen property or was being used to fence stolen property, the Leon good-faith exception could not apply. The Court of Appeals remanded the case to the district court with directions to vacate Ralston’s guilty plea and grant his motion to suppress. View "United States v. Ralston" on Justia Law

The Supreme Court of Kentucky upheld the conviction of Eric Berry, who was found guilty of first-degree burglary, first-degree sexual assault, two counts of fourth-degree assault, first-degree fleeing or evading, and resisting arrest. The court rejected Berry's appeal that his right to a speedy trial was violated, arguing that delays in his trial were due to valid reasons such as Berry's own actions, the COVID-19 pandemic, and personal reasons of his attorneys. The court also denied Berry's argument that the trial court erred in not giving an intoxication defense instruction, stating that while Berry was intoxicated during the incident, he clearly knew what he was doing and acted deliberately. The court further dismissed Berry's claim that his former testimony from a domestic violence hearing should have been allowed, as the Commonwealth did not have an opportunity to cross-examine him during that hearing. Additionally, the court found no error in the joinder of the April and December incidents for the trial, as Berry failed to demonstrate actual prejudice from the record. Lastly, the court rejected Berry's claim for cumulative error, as they found no error in the other arguments presented. View "BERRY V. COMMONWEALTH" on Justia Law