Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion by denying relief.Petitioner alleged in his petition that a number of State actors had been engaged in "deliberately child-predatory and subversionary public nuisance activities" in furtherance of a conspiracy against him. The single justice denied relief. The Supreme Judicial Court affirmed and took measures intended to prevent Petitioner from further abusing the system, holding that the single justice was not obligated to exercise the court's superintendent power to become involved in this matter. View "Kifor v. Commonwealth" on Justia Law

The Supreme Judicial Court declined to address the merits of these appeals challenging the Attorney General's (AG) decision denying Plaintiffs' initiative petition that would have instituted limits on contributions to independent expenditure political action committees, holding that the appeals were moot.The AG determined that the proposed law conflicted with the Massachusetts Declaration of Rights' right of free speech and, therefore, addressed an excluded subject under article 48. Ultimately, the AG concluded that the proposed limitation on campaign contributions was precluded under United States Supreme Court precedent. Plaintiffs appealed. Thereafter, the AG offered to agree to a stipulated order, but Plaintiffs refused to agree with the order. Before the Supreme Judicial Court, the AG argued that the appeals were moot because Plaintiffs did not gather the first round of signatures set forth in article 48. The Supreme Judicial Court dismissed the cases as moot, holding that Plaintiffs failed to meet the deadline to file additional signatures with the Secretary of the Commonwealth. View "Herrmann v. Attorney General" on Justia Law

The Supreme Court affirmed the decision of the district court to deny Petitioner's petition to reinstate his driver's license, holding that the district court did not err in denying the petition because Petitioner did not meet his burden to prove that the suspension of his driver's license was improper.On appeal, Petitioner argued that his request to speak to an attorney prior to taking a preliminary breath test and a post-arrest blood test should not have been taken as an implied refusal to submit to either test and, therefore, he did not refuse to take the tests. The Supreme Court affirmed, holding (1) the record reflected that Petitioner explicitly refused to take the tests; and (2) the district court correctly denied Petitioner's petition. View "Turner v. State" on Justia Law

Rutherford County, Tennessee law enforcement officers raided 23 stores selling cannabidiol (CBD) products because they falsely believed that such products were illegal under state law. The charges were dropped; the products were legal under both state and federal law. The shop owners sued the responsible law enforcement agencies, asserting violations of their constitutional rights and conspiracy to violate those rights. All but one of the shop owners ultimately settled. The district court then granted summary judgment to the County and Sheriff Fitzhugh.On interlocutory appeal, the Sixth Circuit reversed. The plaintiff presented evidence to support a claim of 42 U.S.C. 1983 civil conspiracy. Fitzhugh’s alleged behavior reflects interdependent decision-making with the Smyrna Police Department (SPD) and the DA’s office through the planning and execution of the raids, calculated to achieve an unconstitutional outcome. Although SPD’s raid of the plaintiff’s business was the overt act that directly caused the plaintiff’s alleged injury, holding the county defendants liable for their alleged involvement in the overall plan that led to that raid is the kind of conspiratorial behavior at the heart of section 1983 civil conspiracy claims. A jury could reasonably conclude that there was a “single plan” in which Fitzhugh participated. View "Rieves v. Smyrna, Tennessee" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful possession of a firearm, holding that the did not abuse its discretion in denying Defendant's motion for discovery, and there was no error in the proceedings below warranting a new trial.Defendant's conviction arose from a police investigation into a report of a shooting in a crowded residential area and the ensuing discovery of a firearm allegedly discarded by Defendant. Before trial, Defendant filed a motion for discovery of police reports that he argued was relevant and material to the question of whether the investigation was motivated by race, in violation of his constitutional equal protection rights. The trial judge denied the motion, and Defendant was subsequently convicted. The Supreme Judicial Court affirmed, holding (1) there was no abuse of discretion in the denial of Defendant's motion for discovery; and (2) some of the prosecutor's remarks during closing argument were improper, but the remarks did not warrant a new trial. View "Commonwealth v. Cuffee" on Justia Law

The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence seized from his person during a stop and pat-frisk, holding that the new standard adopted in Commonwealth v. Long, 485 Mass. 711, 724-725 (2020), is applicable in the context of police investigations such as pedestrian stops in addition motor vehicle stops.Defendant was indicted on firearm-related charges after he was stopped by police officers while walking. In his motion to suppress, Defendant argued that the stop was unconstitutional because the officers lacked reasonable suspicion and because statistical evidence proved the officers were more likely to stop Black members of the community than individuals of other races. In addressing Defendant's equal protection challenge, the lower court presumed that this Court's standard for establishing an equal protection claim under the Massachusetts Declaration of Rights, which was adopted to provide a defendant a more accessible path to pursuing an equal protection claim in the context of a motor vehicle stop, applied equally to this pedestrian stop challenge. The Supreme Judicial Court affirmed, holding (1) the new standard adopted in Long is applicable in this case; and (2) the evidence supported the trial court's determination that the officers stopped Defendant to investigate his involvement in the shooting and not because of his race. View "Commonwealth v. Robinson-Van Rader" on Justia Law

Plaintiff was detained beyond the expiration of his sentence because Department officials gave him credit for time served in pre-trial detention but only for one (rather than both) of his two consecutive sentences. That was the right thing to do under the law, then in effect. But Plaintiff was entitled to the more generous provision in effect at the time his sentence was entered. As a result, he served over a year longer than he should have. After his release, Plaintiff brought suit against various Louisiana officials under 42 U.S.C. Section 1983, among other claims. This appeal concerns only one of those claims: Plaintiff’s claim against the head of the Department, Secretary James LeBlanc (“Defendant”). Defendant appealed the denial of qualified immunity, arguing that his conduct wasn’t objectively unreasonable in light of clearly established law.   The Fifth Circuit reversed. The court explained that while the right to timely release is clearly established, Plaintiff does not show how Defendant’s conduct was objectively unreasonable in light of clearly established law. Plaintiff contends that Defendant was objectively unreasonable because he failed to assign the task of calculating release dates to an attorney. But nothing in the Constitution requires that such actions be undertaken by a member of the bar. View "Taylor v. LeBlanc" on Justia Law

Fox TV obtained permission from Superintendent Dixon to film scenes for the television series, Empire, at the Cook County Juvenile Temporary Detention Center. Fox used the Center’s outdoor yard, visitation room, medical office, and certain living spaces for five days and returned to film retakes on seven additional days. During filming, several housing pods housed more detainees than the Center’s policy suggested; some detainees exercised indoors instead of in the outdoor yard; some classes were moved; and the Center postponed or canceled some extra‐curricular activities and held visitation hours in a smaller room.Three detainees filed a proposed class action lawsuit under 42 U.S.C. 1983. The district court granted Dixon partial summary judgment on qualified immunity grounds because the plaintiffs had not shown “a clearly established right to be free of the arguably modest disruptions” but did not dismiss state law claims. The court reasoned that Dixon acted as the detainees’ guardian and had a fiduciary duty to “protect [them] from harm.” Under the holding, Dixon would only be entitled to sovereign immunity on the state law breach of fiduciary duty claim if he proved that he did not violate the detainees’ constitutional rights. On interlocutory appeal, the Seventh Circuit held that Dixon is immune from suit under the Illinois State Lawsuit Immunity Act. The alleged wrongful conduct arose from decisions Dixon made within the scope of his authority. View "T. S. v. County of Cook" on Justia Law

On January 6, 2014, Defendant Genting New York LLC, d/b/a Resorts World Casino New York City ("Genting"), closed the Aqueduct Buffet (the "Buffet"), a restaurant located inside the Resorts World Casino (the "Casino") where Plaintiffs worked. Genting gave Plaintiffs no notice of the closure, which took effect the same day and resulted in 177 employees being laid off. The next week, Plaintiffs filed a putative class action against Genting, alleging that its failure to provide notice violated the Worker Adjustment and Retraining Notification Act (the "WARN Act"), and New York Labor Law Section 860 et seq. (the "New York WARN Act"). On cross-motions for summary judgment, the district court denied Plaintiffs' motion and granted Genting's. On appeal, Plaintiffs argue that the district court erred in granting summary judgment for Genting because, they claim, a reasonable jury could only conclude that the Buffet was either an operating unit or a single site of employment under the WARN Acts.   The Second Circuit affirmed in part and vacated in part. The court explained that Genting is not entitled to summary judgment because a reasonable finder of fact could conclude that the Buffet was an operating unit. Likewise, there is also evidence in the record to support the conclusion that the Buffet was not an operating unit. It will be for the finder of fact at trial to weigh the evidence comprising the "somewhat mixed" record in this case to answer the question. The court concluded that the district court erred in granting summary judgment for Genting and in dismissing Plaintiffs' claims under the WARN Acts. View "Roberts v. Genting" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling that Mont. Code Ann. 50-20-109(1)(a), which restricts providers of abortion care to physicians and physician assistants (PAs), violates a woman's fundamental right of privacy, guaranteed by the Montana Constitution, to seek abortion care from a qualified health care provider of her choosing, holding that there was no error.In reaching its decision, the district court concluded that the State failed to "clearly and convincingly demonstrate a medically acknowledged, bona fide health risk which justifies interfering with a patient's fundamental right[....]to choose the health care provider who performs the [abortion] procedure[.]" The Supreme Court affirmed, holding (1) there is no medically acknowledged, bona fide health risk for the State to restrict the availability of abortion care by preventing Advanced Practice Registered Nurses (APRNs) from performing abortions; and (2) therefore, Montanans have the right to seek abortion care from certified APRNs. View "Weems v. State" on Justia Law