Justia Civil Rights Opinion Summaries

The Supreme Court reversed Defendant's convictions for arson and attempted arson and otherwise affirmed, holding that the trial court erred in failing to grant a directed verdict in Defendant's favor as to the counts for arson in the first degree and attempted arson.Specifically, the Supreme Court held (1) hearsay statements regarding the victims' fear of Defendant were admissible under Ky. R. Evid. 803(3)'s state-of-mind exception; (2) the trial court did not err in permitting witnesses to invoke their Fifth Amendment privilege against self-incrimination; (3) the trial court properly precluded Defendant from presenting an aaltperp defense; (4) the trial court properly admitted physical evidence; (5) Defendant was entitled to a directed verdict on the charges of first-degree arson and attempted first-degree arson; (6) Defendant was not entitled to a directed verdict on the charges for murder; (7) Defendant's burglary convictions did not violate double jeopardy protections; and (8) reversal was not required on grounds of cumulative error. View "Martin v. Commonwealth" on Justia Law

The court awarded Plaintiff fees after he prevailed on one of his six causes of action against his former employer ExakTime Innovations, Inc., on his complaint for disability discrimination under the Fair Employment and Housing Act (FEHA) and related causes of action. The jury awarded Plaintiff $130,088 in damages on his claim ExakTime failed to engage in a good faith interactive process with him. Plaintiff appealed from the trial court’s order awarding him $686,795.62 in attorney fees after the court applied a .4 negative multiplier to its $1,144,659.36 adjusted lodestar calculation “to account for [p]laintiff’s counsel’s . . . lack of civility throughout the entire course of this litigation.” Plaintiff contends the $457,863 reduction in attorney fees based on his counsel’s incivility must be reversed.   The Second Appellate District affirmed. The court agreed with the trial court that it may consider an attorney’s pervasive incivility in determining the reasonableness of the requested fees. A court may apply, in its discretion, a positive or negative multiplier to adjust the lodestar calculation—a reasonable rate times a reasonable number of hours—to account for various factors, including attorney skill. The court explained that the record amply supports the trial court’s finding that Plaintiff’s counsel was repeatedly, and apparently intentionally, uncivil to defense counsel—and to the court— throughout the litigation. View "Snoeck v. ExakTime Innovations" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing the complaint brought by Appellant, a certified nursing assistant at Soldiers' Home, a state-funded healthcare facility housing veterans, alleging violations of his constitutional substantive due process rights to a safe work environment, to be free from a state-created danger, and to bodily integrity, holding that there was no error.Appellant brought this action pursuant to 24 U.S.C. 1983 alleging that Appellees violated his substantive due process rights during the COVID-19 pandemic by failing to protect him from harm, to provide safe working environment, and to provide adequate medical and nursing equipment. Appellees filed a motion to dismiss for failure to state a claim, claiming qualified immunity. The district court dismissed the suit. The First Circuit affirmed, holding that where Appellant pointed to no precedent establishing that Appellees' COVID-19 response violated clearly established law, Appellees were entitled to qualified immunity. View "Ablordeppey v. Walsh" on Justia Law

The U.S. Department of Labor brought the underlying lawsuit under the Employee Retirement Income Security Act, alleging that Appellants Brian Bowers and Dexter Kubota sold their company to an employee stock ownership plan (ESOP) at an allegedly inflated value. The government’s case hinged on a single valuation expert, who opined that the plan overpaid for that company. The district court rejected the opinion, and the government lost a bench trial. The district court denied Appellants’ request for attorneys’ fees and nontaxable costs under EAJA, finding that the government’s litigation position was “substantially justified” and that it did not act in bad faith.   The Ninth Circuit affirmed the district court’s denial of attorneys’ fees and nontaxable costs. The panel held that the district court did not abuse its discretion in concluding that the government’s position at trial was substantially justified, and in denying attorneys’ fees and nontaxable costs under EAJA. The panel noted that the government could not rely on red flags alone, such as the “suspicious” circumstances of the ESOP transaction, to defend its litigation position as “substantially justified.” The panel held that the district court abused its discretion in reducing the award of taxable costs because it relied on a clearly erroneous finding of fact in reducing the magistrate judge’s recommended award of taxable costs. View "JULIE SU V. BRIAN BOWERS, ET AL" on Justia Law

Three private contractors providing war-zone security services to the Department of Defense (DOD) appealed a district court order remanding to Nevada state court this suit brought by a group of their employees who guarded DOD bases, equipment, and personnel in Iraq. The guards alleged that their working conditions violated the contractors’ recruiting representations, their employment contracts, and the Theater Wide Internal Security Services II (TWISS II) contract between the contractors and the Department of Defense.The Ninth Circuit reversed. The panel held that the contractors met the limited burden imposed by the federal officer removal statute, 28 U.S.C. Section 1442(a)(1), which permits removal of a civil action against “any officer (or any person acting under that officer) of the United States or of any agency thereof . . . for or relating to any act under color of such office.” To satisfy this requirement, a removing private entity must show that (a) it is a “person” within the meaning of the statute; (b) there is a causal nexus between its actions, taken pursuant to a federal officer’s directions, and the plaintiff’s claims; and (c) it can assert a colorable federal defense. There was no dispute that the contractors, as corporations, were “persons” for purposes of Section 1442(a)(1). The panel held that the contractors sufficiently pleaded that there was a causal nexus between their actions and the guards’ claims. View "NICHOLAS DEFIORE, ET AL V. SOC LLC, ET AL" on Justia Law

Plaintiff appealed from a partial final judgment of the district court dismissing his Connecticut state law claims for defamation and tortious interference with contract against Defendant, who accused Plaintiff of sexual assault in 2015 while the two were students at Yale University. Plaintiff argued that the district court erred in finding (1) Defendant to enjoy absolute quasi-judicial immunity for statements made at the 2018 Yale disciplinary hearing that resulted in Plaintiff’s expulsion from the university and (2) Plaintiff’s tortious interference claims based on Defendant’s original 2015 accusations to be untimely. On preliminary review, the Second Circuit was unable to determine whether Connecticut would recognize the Yale disciplinary hearing at issue as a quasi-judicial proceeding supporting absolute immunity in this case. Accordingly, the court certified questions pertinent to that determination to the Connecticut Supreme Court. That court responded that absolute immunity does not apply in this case because Yale’s disciplinary hearing was not a quasi-judicial proceeding in that it lacked procedural safeguards associated with judicial proceedings.   In response, The Second Circuit affirmed in part, vacated in part, and remanded. The court explained that while the Connecticut Supreme Court recognized the possibility for participants in such a hearing to be shielded by qualified immunity, the Connecticut Supreme Court concluded that Defendant is not presently entitled to dismissal on that ground because Plaintiff’s complaint sufficiently pleads the malice necessary to defeat such immunity. With this guidance as to Connecticut law, the court concluded on this appeal that Plaintiff’s complaint should not have been dismissed against Defendant except as to his tortious interference claim based on 2015 statements, which is untimely. View "Khan v. Yale Univ." on Justia Law

Defendant, a school resource officer, took issue with Plaintiff’s plan for managing her son’s afternoons and eventually sought and obtained arrest warrants for first- and second-degree child cruelty—felonies that are punishable by mandatory prison terms. Plaintiff was arrested, charged with both crimes and spent four days in jail before posting bond. All charges were eventually dismissed. Plaintiff sued Defendant for malicious prosecution under both federal and state law. The district court granted Defendant summary judgment on the ground that she had probable cause to believe that Plaintiff had engaged in both first and second-degree child cruelty.   The Eleventh Circuit reversed. The court, applying the summary-judgment standard, the court that, taken together (1) the facts that Defendant included in the affidavits that she filed in support of the arrest warrants and (2) the material facts that she knew but omitted from those affidavits do not support even arguable probable cause to believe that Plaintiff committed first- or second-degree child cruelty under Georgia law. Accordingly, the court held that Defendant is not entitled to qualified immunity. Further, the court held that Plaintiff presented a genuine dispute about whether Defendant acted with “malice.” Viewing the evidence in the light most favorable to Plaintiff, Defendant had a close relationship with Plaintiff’s son, she felt disrespected by Plaintiff, she sought the arrest warrants very soon thereafter, seemingly without substantial additional investigation, and she inexplicably omitted material exculpatory information from her affidavits. Collectively, those facts give rise to a reasonable inference that Defendant didn’t just make a mistake. View "Kameron Butler v. Charlene Smith" on Justia Law

Vidal-Martinez, a non-citizen, was arrested three times for operating a vehicle while intoxicated. DHS detained him and initiated deportation. Vidal-Martinez filed a habeas petition, arguing that his detention was unconstitutional because it impeded his ability to defend himself against the drunk-driving charges. ICE transferred Vidal-Martinez to county custody “until the completion of [the] criminal matter, then released to his ICE detainer.” Vidal-Martinez was convicted of DUI and sentenced to 236 days in jail. He was then returned to ICE custody. Due to a lack of evidence that he posed a flight risk or a danger to the community, the district court granted Vidal-Martinez’s habeas petition and ordered his release.Vidal-Martinez filed a FOIA request, 5 U.S.C. 552, seeking disclosure from ICE of documents related to his custody transfer. ICE produced 561 pages of responsive documents, some of which contained redactions. Vidal-Martinez challenged ICE’s redactions. ICE submitted a Vaughn index and a declaration from its FOIA officer explaining the legal justification for each redaction, citing attorney-client, work product, deliberative process privileges, and identifying information of government employees. Vidal-Martinez responded that ICE committed criminal conduct by transferring him to Indiana, so the crime-fraud exception to attorney-client privilege applied. The district court granted ICE summary judgment. The Seventh Circuit affirmed, finding no factual foundation in the record for criminal conduct or misconduct by ICE. The district court had an adequate factual basis to evaluate ICE’s withholdings. View "Vidal-Martinez v. United States Department Of Homeland Security" on Justia Law

The Court of Appeals affirmed the order of the appellate division affirming the judgment of Supreme Court denying Defendant's motion to suppress the firearm found in the vehicle he was driving, holding that the People sustained their burden of demonstrating that the inventory search protocol in this case met "the constitutional minimum."Two New York Police Department officers observed Defendant commit multiple traffic infractions while driving, stopped him, and arrested him for carrying a gravity knife in his pocket. At the precinct, the officers conducted an inventory search of the vehicle and recovered a firearm from the truck. Defendant filed a motion to suppress the firearm on the grounds that the NYPD's inventory search protocol was unconstitutional. The motion was denied, and Defendant pled guilty to criminal possession of a firearm. The Court of Appeals affirmed, holding that Defendant failed to overcome the People's proof establishing a valid inventory search protocol. View "People v. Douglas" on Justia Law

The lawsuit giving rise to this appeal challenged the Living Infants Fairness and Equality Act (“LIFE Act”), which regulated abortion procedures in Georgia. Although Appellees claimed at trial that the LIFE Act violated the due-process, equal-protection, and inherent-rights provisions of the Georgia Constitution, those claims were not ruled on below and were not part of this appeal because the trial court concluded that Appellees were entitled to relief on a different ground. Specifically, the trial court concluded that certain provisions of the LIFE Act were void ab initio because, when the LIFE Act was enacted in 2019, those provisions violated the United States Constitution as interpreted by then-controlling-but-since-overruled decisions of the United States Supreme Court. Here, the issue presented for the Georgia Supreme Court came from that ruling, and the Court concluded the trial court erred. "The holdings of United States Supreme Court cases interpreting the United States Constitution that have since been overruled cannot establish that a law was unconstitutional when enacted and therefore cannot render a law void ab initio." The judgment was reversed and the case remanded to the trial court to consider in the first instance Appellees’ other challenges to the LIFE Act. View "Georgia v. Sistersong Women of Color Reproductive Justice, et al." on Justia Law