Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of two counts of second-degree sexual abuse of a minor, holding that the prosecutor did not commit prosecutorial misconduct in the underlying proceedings.On appeal, Defendant argued that the prosecutor committed misconduct in the way he referred to and used the testimony of a forensic interviewer in his opening statement and closing argument. The Supreme Court disagreed and affirmed, holding (1) Defendant failed to establish that the prosecutor's statement violated a clear and unequivocal rule of law; and (2) there was no plain error in the State's closing argument. View "State v. Ward" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying three plaintiffs' motion for summary judgment in this suit brought to challenge the City of Des Moines' use of the state's income offset program to collect automated traffic citation penalties and granting summary judgment in favor of the City, holding that the district court erred in granting summary judgment as to a preemption claim and a claim for unjust enrichment.Specifically, the Supreme Court held that the district court properly dismissed Plaintiffs' claims that, among other things, the City's use of the income offset program amounted to an unconstitutional taking and that their right to procedural due process was violated. As to Plaintiffs' contention that the City's use of the program was preempted by state law, however, the district court reversed in part, holding that the district court erred in dismissing one plaintiff's preemption claim with respect to his requests for declaratory and injunctive relief and in dismissing two plaintiffs' claim for unjust enrichment. The Court remanded this case for further proceedings. View "Livingood v. City of Des Moines" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the decision of the district court denying Appellant's motion for postconviction relief, holding that the court of appeals erred by granting relief on a claim that Appellant did not present to the district court.Appellant filed a motion for postconviction relief asserting that his failure timely to appeal his convictions was due to the ineffective assistance of his counsel. The district court denied the motion. The court of appeals reversed, concluding that the district court did not err in finding that Appellant did not direct counsel to file an appeal but that counsel provided ineffective assistance by failing to consult with Appellant as to whether he wished to appeal. The Supreme Court reversed, holding (1) Appellant did not allege in his postconviction motion that trial counsel failed to consult with him about whether he wanted an appeal; and (2) therefore, the court of appeals erred by reversing the district court's decision on that basis. View "State v. Ammons" on Justia Law

The complaint, filed in September 2021, alleged that “San Francisco’s criminal legal system is in a state of crisis,” as over 400 criminal defendants had cases pending past their statutory deadline for trial. Of the defendants, 178 were in jail, typically locked in cells for 23 hours a day.The trial court dismissed, reasoning that, under the “Ford” decision, one department of a superior court may not restrain the implementation of a judgment entered by another department. On appeal, the defendants challenged the plaintiffs’ taxpayer-standing cause of action based on Penal Code provisions that impose a duty on the courts (and others) to expedite criminal proceedings, including by prioritizing them over civil cases, and to follow specific procedural steps before a criminal trial may be continued beyond statutory time limits.The court of appeal reversed. Ford is not relevant; the plaintiffs did not seek to review, revise, or reverse any decision in an individual criminal case. The court rejected the defendants’ alternative legal challenges, noting that courts must implement calendar management procedures, in accordance with local conditions, to ensure that criminal cases are assigned before the last day permitted for trial. With respect to standing the court stated that the plaintiffs adequately pleaded “waste” or “illegal expenditure” of public funds and did not impermissibly challenge a discretionary act. View "Raju v. Superior Court" on Justia Law

The Supreme Court affirmed Defendant's sentence of death, following resentencing, in connection with his convictions of first degree murder, two counts of forcible rape, and enhancements for personal use of a firearm, holding that any error in the resentencing was harmless beyond a reasonable doubt.When Defendant was convicted in 2000 the jury found true special circumstances for committing murder during a kidnapping and intentional infliction of torture and set the penalty at death. The Supreme Court upheld the guilt judgment but reversed the penalty verdict on the grounds that the trial court erroneously dismissed a juror during penalty phase deliberations. After a retrial, Defendant was again sentenced to death. The Supreme Court affirmed, holding (1) double jeopardy principles did not bar Defendant's penalty retrial; (2) the penalty retrial did not violate due process; (3) Defendant's challenges to the constitutionality of California's death penalty statute were unavailing; and (4) any error brought about by retroactive application of Senate Bill 1437 was harmless beyond a reasonable doubt. View "People v. Wilson" on Justia Law

The DRBA, a bi-state agency created by an interstate compact between Delaware and New Jersey, hired Minor as its Deputy Executive Director in 2009 and terminated him in 2017. Minor, believing he was fired for his support of then-incoming New Jersey Governor Murphy, sued the DRBA and its Commissioners for violating his First Amendment right to political affiliation. The court rejected the Commissioners’ request for qualified immunity, finding that a reasonable jury could conclude that Minor’s responsibilities were purely administrative by the time he was dismissed so that the Commissioners were barred potentially by the First Amendment from firing Minor on account of his politics.The Third Circuit vacated. The district court correctly held that the right of certain employees not to be fired based on political affiliation was clearly established. However, there is a genuine dispute of material fact concerning whether Minor held such a position. The question of immunity must await the determination of facts at trial. Third Circuit precedent requires the district court to “analyze separately, and state findings with respect to, the specific conduct of each [Commissioner]” to learn more about whether each Commissioner could know that his specific conduct violated clearly established rights. View "Minor v. Delaware River & Bay Authority" on Justia Law

Twelve current and former Philadelphia police officers posted highly offensive Facebook messages that glorified violence and denigrated minority groups. The posts became part of an expose by a national online news organization. The officers, who were disciplined or terminated, alleged First Amendment retaliation.The Third Circuit reversed the dismissal of their suit, noting that it did not condone the officers’ conduct and that the city has an interest in protecting the public’s perception of its officers. There were material factual gaps concerning when certain posts were written and by whom and which posts were the basis of the disciplinary actions. With respect to causation, there was unsubstantiated speculation about the impact of the posts, some of which had been public for years. View "Fenico v. City of Philadelphia" on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court denying Defendant's motion to suppress the seizure of his cell phone and its refusal to suppress evidence of child pornography, holding that the warrant authorizing the search of Defendant's electronic devices containing the child-pornography evidence was unsupported by probable cause.On appeal, Defendant argued that the police exceeded the scope of the first warrant by seizing his phone from his wife and that the application for the second warrant did not contain sufficient detail such that a neutral magistrate could determine whether there was probable cause that the alleged objects of the search were pornographic. The First Circuit remanded the case for further proceedings, holding (1) there was no violation of Defendant's constitutional rights in the seizure of his phone under the first warrant; (2) fatal deficiencies in the second affidavit supporting the second warrant resulted in the second search warrant being issued without the required showing of probable cause; and (3) the good-faith exception did not apply, requiring suppression of the evidence. View "United States v. Sheehan" on Justia Law

After Talevski’s move to a nursing home proved problematic, Talevski sued a county-owned nursing home (HHC) under 42 U.S.C. 1983, claiming that HHC’s actions violated rights guaranteed him under the Federal Nursing Home Reform Act (FNHRA). The Seventh Circuit reversed the dismissal of the suit, concluding that the FNHRA rights cited by Talevski—the right to be free from unnecessary chemical restraints and rights to be discharged or transferred only when certain preconditions are met, “unambiguously confer individually enforceable rights on nursing home residents,” presumptively enforceable via section 1983.The Supreme Court affirmed. The FNHRA provisions at issue unambiguously create section 1983-enforceable rights. There is no incompatibility between private enforcement under section 1983 and the remedial scheme that Congress devised. The Court rejected HHC’s argument that, because Congress apparently enacted the FNHRA pursuant to the Spending Clause, Talevski cannot invoke section 1983 to vindicate rights recognized by the FNHRA. FNHRA lacks any indicia of congressional intent to preclude section 1983 enforcement, such as an express private judicial right of action or any other provision that might signify that intent. HHC cited the comprehensiveness of FNHRA’s enforcement mechanisms, but implicit preclusion is shown only by a comprehensive enforcement scheme that is incompatible with individual enforcement under section 1983. There is no indication that private enforcement under section 1983 would thwart Congress’s scheme by circumventing the statutes’ pre-suit procedures, or by giving plaintiffs access to tangible benefits otherwise unavailable under the statutes. View "Health and Hospital Corp. of Marion County v. Talevski" on Justia Law

In 1992, Voting Rights Act (52 U.S.C. 10301) Section 2 litigation challenging Alabama’s districting map resulted in Alabama’s first majority-black district and its first black Representative since 1877. Alabama’s congressional map has remained similar since then. Following the 2020 census, the state enacted a new districting map (HB1), which produced only one district in which black voters constituted a majority.The Supreme Court affirmed a preliminary injunction, prohibiting the use of HB 1.Section 2 provides that the right to vote “shall not be denied or abridged ... on account of race, color, or previous condition of servitude.” A 1982 amendment incorporated an effects test and a disclaimer that “nothing” in Section 2 “establishes a right to have members of a protected class elected in numbers equal to their proportion in the population.” The Supreme Court subsequently employed the “Gingles framework,” under which Section 2 plaintiffs must satisfy three preconditions and then show that, under the “totality of circumstances,” the challenged process is not “equally open” to minority voters.The district court correctly found that black voters could constitute a majority in a second district that was “reasonably configured” and that there was no serious dispute that Black voters are politically cohesive, nor that the challenged districts’ white majority votes sufficiently as a bloc to usually defeat Black voters’ preferred candidate. The court’s findings that “Black Alabamians enjoy virtually zero success in statewide elections” and concerning “Alabama’s extensive history of repugnant racial and voting-related discrimination” were unchallenged.The Court rejected Alabama’s arguments that a state’s map cannot abridge a person’s right to vote “on account of race” if the map resembles a sufficient number of race-neutral alternatives and that the plaintiffs must prove discriminatory intent. Section 2, as applied to redistricting, is not unconstitutional under the Fifteenth Amendment. View "Allen v. Milligan" on Justia Law