Justia Civil Rights Opinion Summaries

The Supreme Court held that Cal. Penal Code 667.6(d), which requires that a sentencing court impose "full, separate, and consecutive" terms for certain sex crimes if it finds certain facts, complies with the Sixth Amendment to the United States Constitution.Defendant was convicted of six counts of forcible lewd acts on a child under the age of fourteen and one lesser-included offense of attempt and sentenced to full, consecutive terms for each of his convictions. On appeal, Defendant argued that the trial court violated his Sixth Amendment right to a jury trial by sentencing him under section 667.6(d) without submitting to the jury the question of whether each of his offenses was committed on a separate occasion. The court of appeal denied relief. The Supreme Court affirmed, holding that the operation of section 667.6(d) does not violate the rule of Apprendi v. New Jersey, 530 U.S. 466 (2000), and Alleyne v. United States, 570 U.S. 99 (2013). View "People v. Catarino" on Justia Law

Younger claims that during his pretrial detention in a Maryland state prison, Lieutenant Dupree ordered guards to attack him. Younger sued Dupree for damages under 42 U.S.C. 1983. The district court denied Dupree’s summary judgment motion, finding no dispute that the Maryland prison system had internally investigated Younger’s assault, which satisfied Younger’s exhaustion obligation. At trial, Dupree did not present evidence relating to his exhaustion defense. The jury found Dupree and four codefendants liable and awarded Younger $700,000 in damages. The Fourth Circuit—bound by its prior holding that any claim or defense rejected at summary judgment is not preserved for appellate review unless it was renewed in a post-trial motion—dismissed an appeal.The Supreme Court vacated. A post-trial motion under Federal Rule of Civil Procedure 50 is not required to preserve for appellate review a purely legal issue resolved at summary judgment. The factual record developed at trial supersedes the record existing at the time of the summary-judgment motion; that is not true for pure questions of law resolved on summary judgment, which are not “supersede[d]” by later developments in the litigation and merge into the final judgment. A reviewing court does not benefit from having a district court reexamine a purely legal pretrial ruling. While an interlocutory order denying summary judgment is typically not immediately appealable, 28 U.S.C. 1291 does not insulate interlocutory orders from appellate scrutiny but rather delays their review until final judgment. The Court did not decide whether Dupree's issue on appeal was purely legal, and remanded for the Fourth Circuit to evaluate that question. View "Dupree v. Younger" on Justia Law

Tyler's Hennepin County, Minnesota condominium accumulated about $15,000 in unpaid real estate taxes plus interest and penalties. The County seized the condo and sold it for $40,000, keeping the $25,000 excess over Tyler’s tax debt for itself, Minn. Stat. 281.18, 282.07, 282.08. The Eighth Circuit affirmed the dismissal of Tyler’s suit.The Supreme Court reversed. Tyler plausibly alleges that Hennepin County’s retention of the excess value of her home above her debt violated the Takings Clause. Whether the remaining value from a tax sale is property protected under the Takings Clause depends on state law, “traditional property law principles,” historical practice, and Supreme Court precedents. Though state law is an important source of property rights, it cannot “sidestep the Takings Clause by disavowing traditional property interests” in assets it wishes to appropriate. The County's use of its power to sell Tyler’s home to recover the unpaid property taxes to confiscate more property than was due effected a “classic taking in which the government directly appropriates private property for its own use.” Supreme Court precedent recognizes that a taxpayer is entitled to any surplus in excess of the debt owed. Minnesota law itself recognizes in other contexts that a property owner is entitled to any surplus in excess of her debt. The Court rejected an argument that Tyler had no property interest in the surplus because she constructively abandoned her home by failing to pay her taxes. View "Tyler v. Hennepin County" on Justia Law

Plaintiffs brought multiple claims against various defendants pursuant to 42 U.S.C. Section 1983. As relevant here, they asserted two general categories of claims—that the officers used excessive force in executing the search warrant and that the search and seizure were unlawful. As against the individual officers, Plaintiffs asserted both direct claims and claims premised on failure to intervene. And as against Lieutenants, Plaintiffs asserted that the two lieutenants are directly liable for excessive-force and search-and-seizure and liable on a failure to supervise theory. Finally, Plaintiffs also asserted wrongful death and survival as separate “causes of actions,” in their words. Several of the officers moved to dismiss, asserting qualified immunity.   The Fifth Circuit affirmed in part, reversed in part, and vacated in part. The court affirmed the aspects of the judgment denying the motions to dismiss the excessive-force claims asserted against several co-Defendants and denying one Lieutenant’s motion to dismiss as to Plaintiffs’ excessive force and search-and-seizure claims premised on a failure-to-supervise theory.   The court reversed the district court’s ruling denying the Lieutenant’s motion to dismiss the excessive force and search-and-seizure claims based on direct liability. The court concluded that this was error because the Lieutenant was not personally involved in obtaining the search warrant or in effectuating the search. “Personal involvement is an essential element” of demonstrating liability under Section 1983. View "Tuttle v. Sepolio" on Justia Law

Plaintiff obtained a $425,562 jury verdict in his favor on his claim that the California Department of Tax and Fee Administration (the Department) retaliated against him for filing an internal complaint with its Equal Opportunity Office (EEO). The Department appealed, contending that four erroneous evidentiary rulings by the trial court deprived it of a fair trial.   The Second Appellate District reversed. The court agreed that the trial court erred in admitting evidence about activity that occurred before the filing of his EEO complaints. The court also concluded that admission of the first EEO complaint and supplement was prejudicial and prevented the Department from receiving a fair trial. The court explained that there is no doubt that the fact that Plaintiff filed an EEO complaint for age and race discrimination is highly relevant. It is the protected activity needed for his claim; more colloquially, it provides a motive for the retaliation. The details of the discrimination are not relevant. This was not a trial about whether Plaintiff’s co-worker engaged in race or age discrimination; Plaintiff waived those claims in the prior settlement agreement. Accordingly, the court reversed the judgment and remanded for further proceedings. The court wrote that it need not and does not reach the Department’s other claims of error. View "Kourounian v. Cal. Dept. of Tax & Fee Administration" on Justia Law

In 2011, Gaona fired a gun with the intent to kill a certain individual but accidentally shot and injured a bystander. Gaona pleaded guilty in Michigan state court to assault with intent to murder and possession of a firearm during the commission of a felony. Gaona was sentenced to two years for the firearm conviction, consecutive to a 17-to-50-year sentence for the assault conviction, based on a PSR which reported three prior misdemeanors, including one stemming from a 2009 incident, for which Gaona was (without the assistance of counsel) convicted of possession of marijuana via plea and sentenced to 30 days’ time served. The Michigan Court of Appeals rejected his argument that state courts may not rely on an uncounseled misdemeanor conviction in enhancing a sentence if that conviction resulted in a sentence of actual imprisonment.The district court denied Gaona’s 28 U.S.C. 2254 habeas corpus petition on the same sentencing argument but stayed his petition so that he could exhaust his ineffective assistance of counsel claim in state court. The state courts rejected those claims. The federal court then rejected his ineffective assistance claims as he had not filed an amended habeas petition. The Sixth Circuit affirmed. No Supreme Court case clearly establishes that state courts may not, in enhancing a sentence, rely on an uncounseled misdemeanor that resulted in a sentence of time served. View "Gaona v. Brown" on Justia Law

Plaintiff is a deaf man who can understand only about 30% of verbal communication through lipreading. He communicates primarily through American Sign Language (ASL). Plaintiff worked for O’Reilly Auto Parts (O’Reilly) as an inbound materials handler. He claims that the company discriminated against him in violation of Title I of the Americans with Disabilities Act (ADA) because it did not provide him with the reasonable accommodations that he requested for his disability. He alleged that he requested but did not receive an ASL interpreter for various meetings, training, and a company picnic. He also alleged that he asked for text messages summarizing nightly pre-shift meetings but did not receive them either. The district court, acting by consent through a magistrate judge, granted O’Reilly’s motion for summary judgment on Plaintiff’s ADA claim.   The Eleventh Circuit reversed the district court’s grant of summary judgment in favor of O’Reilly. The court remanded for further proceedings involving Plaintiff’s claim that O’Reilly violated the ADA by failing to provide him with reasonable accommodations regarding the nightly pre-shift safety meetings and regarding his disciplinary proceedings involving attendance issues. The court concluded that genuine issues of material fact do exist about whether two of Plaintiff’s requested accommodations relate to his essential job functions and whether the failure to provide those two accommodations led to an “adverse employment decision.” If Plaintiff’s allegations turn out to be the actual facts, there was a violation of Title I of the ADA, and that means summary judgment against him was inappropriate. View "Teddy Beasley v. O'Reilly Auto Parts" on Justia Law

Xi and his wife, Li, immigrated to the U.S. from China in 1989. Xi, an internationally acclaimed expert on thin film superconducting technology, became Chair of the Physics Department at Temple University. On May 21, 2015, Xi answered the door and was confronted by armed FBI agents. Agents held the family at gunpoint and conducted an extensive search before taking Xi to the FBI’s field office. He was interrogated before the agents revealed that Xi had been indicted for providing Chinese entities with sensitive information about a “revolution[ary]” superconductor, the “pocket heater.” Eventually, prosecutors realized that, as the inventor allegedly explained, Xi’s emails did not concern the pocket heater and the pocket heater was not “revolutionary.” The government moved to dismiss the Indictment. The case received widespread media attention. Temple placed Xi on administrative leave; the family suffered emotionally and financially.The district court dismissed Xi's “Bivens” claims alleging equal protection and Fourth Amendment violations, malicious prosecution, and fabrication of evidence, and the family's Federal Tort Claims Act (FTCA), 28 U.S.C. 1346(b) claims. The court determined that Xi failed to allege “clearly established” constitutional violations and assumed that the same qualified immunity standard applied to the FTCA’s “discretionary function exception.”The Third Circuit affirmed in part, citing Supreme Court precedent declining to extend Bivens into the national security realm and the limited circumstances in which Congress has provided a remedy. The court vacated the dismissal of the FTCA claims. The “clearly established” threshold is inapplicable. The government has no discretion to violate the Constitution; FTCA claims premised on conduct that is plausibly alleged to violate the Constitution may not be dismissed on the basis of the discretionary function exception. View "Xi v. Haugen" on Justia Law

Plaintiff was arrested for driving while intoxicated. She sued under 42 U.S.C. Section 1983 and related state laws. The district court granted summary judgment to Defendants, dismissing all of Plaintiff’s claims. On appeal, Plaintiff contests the summary judgment for the Section 1983 claims of false arrest and excessive force along with the state law claims of false arrest, excessive force, negligence, and vicarious liability.   The Fifth Circuit affirmed. The court concluded that the officers had probable cause to arrest Plaintiff for driving while intoxicated. The court explained that the following facts are confirmed: (1) A witness reported to the police that Plaintiff was driving in a dangerous manner;(2) there is video footage of Plaintiff’s car swerving out of the lane and recorded audio of the officers noting the swerve, and (3) The officers could not conclusively determine that she had not taken drugs. Those facts alone are sufficient to give rise to probable cause that Plaintiff was driving while intoxicated. Further, the court found that the officer’s limited use of force (in such a short time frame) to restrain Plaintiff and place her in handcuffs as a response to Plaintiff’s perceived resistance does not amount to excessive force.   Moreover, the court found that the officers had probable cause to arrest Plaintiff for driving while intoxicated, and accordingly, there was no false arrest. Finally, because Plaintiff’s underlying state law claims were properly dismissed, there is no basis for her vicarious liability claim against the municipal Defendants. View "Scott v. City of Mandeville, et al" on Justia Law

Police found Miller lying on the sidewalk, bleeding from an apparent gunshot wound. An officer rendering aid removed a vehicle key fob from Miller’s hand, dropping it on the ground. A car, parked 15-20 feet from Miller, had bullet holes in the rear driver’s side door. Officers checked whether there was anyone in the car. One officer shined his flashlight through the windshield and saw what he thought was blood on the front passenger seat. An officer picked up the key fob and clicked a button. The car’s horn honked. Minutes later, an officer stated that he could see the barrel of a gun sticking out from under a hat on the front passenger seat. The car was towed to the police station. At the hospital, Miller said that he was using his girlfriend’s car. A database check showed that the impounded car was registered to Miller. The police obtained a warrant to search the car without mentioning the key fob. Police recovered the gun. DNA on the gun matched Miller’s. He was indicted for possessing a firearm as a felon.The Seventh Circuit upheld the denial of Miller’s motion to suppress. Miller argued that clicking the key fob qualified as a search. The district judge reasoned that the fob was used only to identify the car, not to gain entry, and that Miller had no reasonable expectation of privacy in the identity of his car. The Seventh Circuit reasoned that the evidence was also admissible under the independent source doctrine. The car would have been searched regardless of the identity of its owner. View "United States v. Miller" on Justia Law