Justia Civil Rights Opinion Summaries

Tad Mayfield, a nonpartisan legislative specialist in the assistant chief clerk’s office of the Missouri House of Representatives, was terminated on August 6, 2020, after sending an email on August 3, 2020, to the Speaker of the House and the President Pro Tem of the Missouri Senate advocating for mandatory face masks in the state capitol building due to COVID-19 concerns. Mayfield filed a lawsuit under 42 U.S.C. § 1983, alleging wrongful termination in retaliation for his email, claiming it violated his First Amendment rights.The case proceeded to a jury trial in the United States District Court for the Western District of Missouri. The jury found in favor of Mayfield, awarding him $15,000 in punitive damages and $14,993.93 in actual damages for lost wages. The district court denied the defendants' motions for judgment as a matter of law and awarded Mayfield attorney’s fees.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Mayfield’s email was protected speech under the First Amendment as it addressed a matter of public concern. The court found that the defendants failed to show that the email had an adverse impact on the efficiency of the House’s operations, which would have necessitated a Pickering balancing test. The court also upheld the jury’s finding that the email was a substantial or motivating factor in Mayfield’s termination and rejected the defendants' claim of qualified immunity, stating that the right to speak on matters of public concern was clearly established.Additionally, the court found sufficient evidence to support the submission of punitive damages to the jury, given the defendants' knowledge that terminating an employee for raising public health concerns could be illegal. The court also upheld the district court’s award of attorney’s fees to Mayfield, finding no abuse of discretion. View "Mayfield v. Miller" on Justia Law

Silvia Cianzio, a retired professor from Iowa State University, filed a lawsuit against the university, the Iowa Board of Regents, and the State of Iowa, alleging wage discrimination in violation of Iowa Code section 216.6A. She claimed that male professors in her department were paid significantly more than female professors, including herself. After conducting a survey on departmental salaries, she discovered that her annual pay was substantially less than that of her male counterparts. She reported these findings to university officials, who dismissed her concerns. Cianzio retired in December 2020 and subsequently filed a complaint with the Iowa Civil Rights Commission (ICRC) in August 2021, followed by a lawsuit in January 2022.The Iowa District Court for Polk County partially granted the university's motion to dismiss, ruling that Cianzio could only seek damages for wage discrimination occurring within the two-year statute of limitations for wage claims, as set forth in Iowa Code section 614.1(8). The court rejected the university's argument that damages should be limited to the 300-day period preceding the filing of her ICRC complaint.The Iowa Supreme Court reviewed the case and reversed the district court's decision. The court held that Iowa Code section 216.15(9)(a)(9) allows a claimant to recover damages for the entire period of wage discrimination, not limited to the two-year statute of limitations or the 300-day period before filing the ICRC complaint. The court emphasized that the statute's language permits recovery for the entire period of discrimination, as long as the complaint is filed within the statutory time frame. The case was remanded for further proceedings consistent with this interpretation. View "Cianzio v. Iowa State University" on Justia Law

The case involves a defendant charged with multiple first-degree sexual offenses against a victim, J, who has an intellectual disability. The defendant did not dispute J's disability but argued that she was capable of consenting to the sexual acts. The trial court denied the defendant's motion for judgment of acquittal, and a jury convicted him of various charges. The defendant appealed, arguing that the state failed to prove that J's disability rendered her incapable of appraising the nature of her conduct.The Oregon Court of Appeals, in a divided decision, reversed the trial court's judgment, concluding that the evidence was insufficient to show that J was incapable of understanding the sexual nature of the conduct or exercising judgment to consent to it. The state petitioned for review, challenging the Court of Appeals' interpretation and application of the relevant statutes.The Oregon Supreme Court reviewed the case, focusing on the interpretation of ORS 163.305(3) and ORS 163.315(1)(b), which define when a person is incapable of consenting to a sexual act due to a mental defect. The court clarified that to be capable of consent, a person must be able to appraise the nature of their conduct, which involves exercising judgment and making choices based on an understanding of the conduct's significance. The court emphasized that the state must prove that the person's intellectual disability prevented them from appraising the nature of the conduct at the time of the alleged offense.The Oregon Supreme Court concluded that the evidence presented at trial was sufficient to allow a rational jury to find that J's intellectual disability rendered her incapable of appraising the nature of her conduct. Therefore, the trial court did not err in denying the defendant's motion for judgment of acquittal. The court reversed the decision of the Court of Appeals and affirmed the trial court's judgment in part, but reversed the conviction on Count 5 due to a nonunanimous jury verdict, remanding for further proceedings. View "State v. Wallace" on Justia Law

Alejandro Martinez was walking home when Officer Cantu stopped him for walking on the wrong side of the street, in violation of the Texas Transportation Code. Martinez initially complied but then walked away. Cantu took Martinez to the ground to handcuff him. Other officers arrived, and Martinez was taken to a hospital, where he was found to have no serious injuries and was cleared for jail.Martinez sued the City of Rosenberg and several officers under 42 U.S.C. § 1983, alleging unlawful arrest and excessive force. The United States District Court for the Southern District of Texas dismissed the municipal liability claim against the City for failure to state a claim under Monell v. Department of Social Services of the City of New York. The court also granted summary judgment for the officers on qualified immunity grounds, finding no constitutional violations.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's dismissal of the Monell claim, agreeing that Martinez's complaint was conclusory and lacked factual support. The court also affirmed the summary judgment for the officers, finding that Officer Cantu had probable cause to arrest Martinez for violating the Texas Transportation Code and that the force used was reasonable. The court noted that Martinez's injuries were de minimis and that the bystander liability claim could not stand without an underlying constitutional violation. The court concluded that the officers were protected by qualified immunity and affirmed the district court's judgment. View "Martinez v. City of Rosenberg" on Justia Law

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