Justia Civil Rights Opinion Summaries

Tam Steven Nguyen committed various crimes at the age of 22 and was convicted in 2003 of attempted murder, kidnapping, and assault with a firearm. The jury also found true firearm allegations. He was sentenced to a determinate term of 14 years, an indeterminate term of 25 years to life, and a life term with the possibility of parole. While incarcerated, Nguyen earned various credits, including good conduct and educational merit credits. His minimum eligible parole date (MEPD) is set for February 2036, and his youth parole eligible date (YPED) is set for October 2026.Nguyen petitioned the trial court for a writ of habeas corpus in 2022, arguing that he should be allowed to use all earned credits to advance his YPED, not just educational merit credit. The trial court denied his petition. Nguyen then petitioned the California Court of Appeal, which summarily denied the petition. The California Supreme Court granted review, ordered the appellate court to vacate its order, and issue an order to show cause.The California Court of Appeal reviewed the case and held that Nguyen's right to equal protection was not violated. The court found that youth and nonyouth offenders are not similarly situated for the purposes of the challenged regulations, as youth offenders have two parole eligibility dates (MEPD and YPED) while nonyouth offenders have only one (MEPD). The court also determined that there is a rational basis for the regulation, as it aligns with the legislative intent to provide youth offenders with a meaningful opportunity for release while maintaining a relatively fixed YPED. Consequently, the court denied Nguyen's petition for writ of habeas corpus. View "In re Nguyen" on Justia Law

Lloyd Gerald Napouk was fatally shot by two Las Vegas Metropolitan Police Department officers after they responded to reports of a man behaving suspiciously in a residential neighborhood with what appeared to be a long, bladed weapon. The officers attempted to engage Napouk, who refused to follow their commands and advanced towards them multiple times. When Napouk came within nine feet of one of the officers, both officers fired their weapons, killing him. The weapon turned out to be a plastic toy fashioned to look like a blade.Napouk’s parents and estate sued the officers and the Las Vegas Metropolitan Police Department, alleging excessive force in violation of the Fourth Amendment, deprivation of familial relations in violation of the Fourteenth Amendment, municipal liability based on Monell v. Department of Social Services, and Nevada state law claims. The United States District Court for the District of Nevada granted summary judgment for the defendants, determining that the officers’ use of force was reasonable as a matter of law.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment. The court held that the officers were entitled to qualified immunity from the Fourth Amendment excessive force claim because Napouk posed an immediate threat to the officers, and no rational jury could find the officers’ mistake of fact regarding the weapon unreasonable. The court also held that the plaintiffs’ Fourteenth Amendment claim failed because there was no evidence that the officers acted with anything other than legitimate law enforcement objectives. Additionally, the plaintiffs’ Monell claims failed due to the absence of a constitutional violation, and the state law claims failed because the officers were entitled to discretionary-function immunity under Nevada law. View "Napouk v. Las Vegas Metropolitan Police Department" on Justia Law

Joseph Corcoran was convicted of four murders by an Allen County jury, and the judge sentenced him to death as recommended by the jury. Corcoran has been involved in extensive litigation over the past 25 years, including multiple decisions from the Indiana Supreme Court and the United States Supreme Court, regarding the constitutionality of his execution. Corcoran has expressed his desire to accept his conviction and sentence, stating that he does not wish to pursue further legal challenges.The Allen Superior Court initially sentenced Corcoran to death, and the Indiana Supreme Court remanded for resentencing due to the consideration of non-statutory aggravating factors. Upon resentencing, the death sentence was reimposed and affirmed by the Indiana Supreme Court. Corcoran chose not to pursue post-conviction relief, leading to competency proceedings initiated by the State Public Defender, who argued that Corcoran was incompetent to waive post-conviction remedies. The trial court and the Indiana Supreme Court found Corcoran competent. Corcoran later filed an untimely petition for post-conviction relief, which was dismissed.The Indiana Supreme Court reviewed the case and denied the State Public Defender's motions to file successive petitions for post-conviction relief and to stay the execution. The court held that Corcoran is competent to waive post-conviction remedies and that the State Public Defender lacks standing to file the petitions without Corcoran's authorization. Additionally, the court found no reasonable possibility that Corcoran is entitled to relief, as the claims presented were procedurally defaulted and previously addressed. The court concluded that Corcoran has a rational understanding of his execution and the reasons for it, and thus, denied the motions for a stay of execution. View "Corcoran v. State" on Justia Law

Matthew Cartia and Autumn Adams were arrested by officers when they attempted to interfere with a police investigation at Cartia's parents' house. The officers claimed that Cartia and Adams were interfering with their work, leading to a confrontation where Cartia was handcuffed and taken down using a "hip-toss" maneuver. Adams was also arrested after she tried to intervene. Both Cartia and Adams alleged that the officers used excessive force during and after their arrests, including claims that Cartia was struck and choked by the officers.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the defendants, including the officers and Lincoln County. The magistrate judge concluded that the officers were entitled to qualified immunity and that Lincoln County was not liable under Monell for the officers' actions.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the grant of summary judgment for some claims but reversed it for others. The court held that the officers were entitled to qualified immunity for most of their actions, including the initial takedown and restraint of Cartia, as well as the force used against Adams. However, the court found that there were genuine issues of material fact regarding the excessive force claims against Officers Beeman and Gugliano for allegedly striking and choking Cartia after he was subdued. These claims were remanded for further proceedings. The court also found that the state law claims of assault and battery and negligence against these officers should proceed to trial, as there was sufficient evidence to suggest they may have acted with malice or bad faith. The court affirmed the dismissal of the remaining claims. View "Cartia v. Beeman" on Justia Law

Andre Louis Keller drove to a permanent immigration checkpoint where a Customs & Border Protection (CBP) canine alerted to his vehicle. Upon searching, agents found an alien unlawfully present in the United States concealed under luggage. Keller conditionally pleaded guilty and appealed the district court’s denial of his motion to suppress the evidence found in the vehicle.The United States District Court for the Southern District of Texas held a hearing on Keller’s motion to suppress. Testimonies were provided by CBP Agent Jesse Sandoval, Matthew B. Devaney from CBP’s Canine Academy, and Andre Falco Jimenez, a private police dog trainer. The district court denied Keller’s motion, leading to his conditional guilty plea. Keller was sentenced to 20 months in prison and 3 years of supervised release. He then appealed the suppression ruling.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that stopping a vehicle for brief questioning at a permanent immigration checkpoint is not a Fourth Amendment search and does not require probable cause. The court found that the canine’s alert provided probable cause to search Keller’s vehicle. The court also concluded that the canine’s actions did not constitute an unlawful search and that the district court did not err in its ruling. The Fifth Circuit affirmed the district court’s denial of Keller’s motion to suppress. View "United States v. Keller" on Justia Law

C.H., an eleven-year-old, was sexually exploited by a stranger on Omegle.com, an online platform that connects users in video chatrooms. The stranger, referred to as John Doe, threatened C.H. into creating child pornography. C.H.'s parents sued Omegle.com LLC, alleging violations of 18 U.S.C. § 2255 (Masha’s Law) for knowingly possessing child pornography and the Trafficking Victims Protection Reauthorization Act for knowingly benefiting from a sex trafficking venture.The United States District Court for the Middle District of Florida dismissed the claims, citing section 230 of the Communications Decency Act, which protects providers of interactive computer services from being treated as the publisher or speaker of user-provided information. The court also found that the sex trafficking claim did not meet the Fight Online Sex Trafficking Act (FOSTA) exception to section 230 because C.H.'s parents did not allege that Omegle.com had actual knowledge of benefiting from sex trafficking.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that C.H.'s parents did not state a claim under Masha’s Law because they failed to allege that Omegle.com knowingly possessed or accessed child pornography. The court also held that the FOSTA exception to section 230 requires actual knowledge of sex trafficking, not just constructive knowledge. Since C.H.'s parents did not plausibly allege that Omegle.com had actual knowledge of the sex trafficking incident involving C.H., the court affirmed the district court's dismissal of the claims. View "M.H., et al. v. Omegle.com LLC" on Justia Law

Dr. Tara Gustilo, an Asian American obstetrician-gynecologist of Filipino descent, was demoted from her position as Chair of the OBGYN Department at Hennepin Healthcare System, Inc. (HHS) in April 2021. Following her demotion, she filed charges with the Equal Employment Opportunity Commission (EEOC) and subsequently sued HHS, alleging race discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA), as well as a First Amendment retaliation claim under 42 U.S.C. § 1983.The United States District Court for the District of Minnesota granted summary judgment in favor of HHS, finding no genuine dispute of material fact regarding the race discrimination, retaliation, and First Amendment claims. The court concluded that Dr. Gustilo failed to establish a prima facie case of race discrimination and that there was no evidence she opposed an unlawful employment practice. Additionally, the court found no material fact dispute regarding whether the HHS Board considered her Facebook posts in its decision to demote her.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court reversed the district court's grant of summary judgment on the First Amendment retaliation claim, finding that there was a material fact dispute regarding whether the HHS Board ratified the MEC's decision and the basis for it, which included consideration of Dr. Gustilo's Facebook posts. The court remanded the case for further proceedings to determine if the posts were protected speech and to apply the Pickering balancing test.The court declined to review the district court's summary judgment rulings on the Title VII and MHRA claims at this time, as they are now interlocutory. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Gustilo v. Hennepin Healthcare System, Inc." on Justia Law

One night, Officer Devosie Jones of the City of Remerton Police Department attempted to stop a black Cadillac with one headlight. The car did not stop, leading to a high-speed chase that ended when the Cadillac crashed into a tree. Quinton Simmons was found trying to exit the car and was arrested. Officers found narcotics and a firearm in the vehicle. Simmons was charged with possession of methamphetamine with intent to distribute, possession of a firearm by a convicted felon, and possession of a firearm in furtherance of a drug trafficking crime. He pleaded not guilty, claiming he was kidnapped and framed by a gang member who fled the scene.The United States District Court for the Middle District of Georgia denied Simmons's Batson challenge, accepting the government's race-neutral reasons for striking three black jurors. During the trial, the court allowed the government to play a brief segment of a body camera video but denied Simmons's request to play additional clips during closing arguments, as they had not been shown during the evidence phase. The jury found Simmons guilty on all counts.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the district court did not abuse its discretion in limiting the scope of closing arguments, as Simmons had the opportunity to present the video clips during the trial but chose not to. The court also found no error in the district court's denial of the Batson challenge, as Simmons failed to make a prima facie case of racial discrimination, and the government's race-neutral explanations were credible. The Eleventh Circuit affirmed the district court's judgment. View "United States v. Simmons" on Justia Law

A newspaper, Copley Ohio Newspapers, Inc., doing business as Akron Beacon Journal, made several public-records requests to the City of Akron and the Akron Police Department in 2022. The requests sought records identifying police officers involved in three lethal use-of-force incidents. The city provided some records but redacted the officers' names, citing safety concerns and legal exceptions. The newspaper filed a mandamus action under the Ohio Public Records Act, R.C. 149.43, to compel the city to produce unredacted records.The lower court, the Supreme Court of Ohio, reviewed the case. The city argued that the requests for personnel files, discipline records, and internal investigations of unidentified officers were improper public-records requests and that the officers' names were protected under the confidential law-enforcement investigatory records (CLEIR) exception and the Kallstrom/Keller exception, which protects records that could endanger officers' lives.The Supreme Court of Ohio held that the requests for personnel files, discipline records, and internal investigations of unidentified officers were improper public-records requests. However, the court found that the requests for administrative leave or reinstatement notices and incident reports were proper. The court ruled that the names of the officers involved in the Walker shooting were exempt from disclosure under the CLEIR exception for uncharged suspects. The court ordered the city to provide copies of the Walker incident reports with only the names of the eight officers who are uncharged suspects redacted and to provide unredacted copies of the administrative leave and reinstatement notices. The court denied the newspaper's requests for statutory damages and attorney fees but granted court costs. View "State ex rel. Copley Ohio Newspapers, Inc. v. Akron" on Justia Law

Plaintiffs Luther C. Parente and Eric L. Stewart sued the Rhode Island Department of Corrections (RIDOC) and its staff for failing to properly treat their preexisting medical conditions. They alleged various federal and state constitutional, statutory, and common law bases for relief, including a claim under the Rhode Island Civil Rights Act of 1990 (RICRA). The plaintiffs claimed that RIDOC's medical and correctional staff failed to meet their medical needs, resulting in harm and discrimination.The United States District Court for the District of Rhode Island denied RIDOC's motion for summary judgment on Eleventh Amendment grounds as to the RICRA claim. The district court held that Rhode Island's general waiver of sovereign immunity under the State Tort Claims Act applied to RICRA claims, reasoning that discrimination actions under RICRA sounded in tort. RIDOC appealed this decision, arguing that the district court erred in holding that violations of civil rights under RICRA were subject to the general waiver of Eleventh Amendment immunity.The United States Court of Appeals for the First Circuit reviewed the case and determined that there was a "special reason" to certify the underlying state-law issue to the Rhode Island Supreme Court. The appellate court noted that the question of whether RICRA claims are "actions of tort" under the State Tort Claims Act is a matter of state law that has not been definitively resolved by the Rhode Island Supreme Court. Therefore, the First Circuit certified the question to the Rhode Island Supreme Court to determine whether discrimination claims under RICRA are covered by the general waiver of sovereign immunity under the State Tort Claims Act. The First Circuit retained jurisdiction over the issue pending resolution of the certified question. View "Parente v. Lefebvre" on Justia Law