Justia Civil Rights Opinion Summaries

Breion Woodson was convicted in Wisconsin state court on charges of firearm and drug possession and sentenced to 19 years in prison. During sentencing, the government presented a video from social media showing men with guns and drugs, which the judge used to assess Woodson's character and danger to the community. Woodson argued that he was misidentified in the video, but the judge denied his motion for a new sentencing hearing. The Wisconsin Court of Appeals affirmed, stating Woodson failed to prove he was not the man in the video.Woodson then filed a federal habeas corpus petition in the Eastern District of Wisconsin, introducing booking photos from the time of his sentencing that suggested he was not the man in the video. However, the district court ruled it could not consider the photos since they were not presented in state court and denied his petition, finding the state appellate court's decision reasonable based on the evidence it had.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that under the Antiterrorism and Effective Death Penalty Act (AEDPA), habeas relief is unavailable unless the state court's decision was contrary to or an unreasonable application of federal law or based on an unreasonable determination of facts. The court found that Woodson's claim was not procedurally defaulted and that the actual innocence exception did not apply to his case. The court also ruled that it could not consider the new evidence (booking photos) under AEDPA's strict limitations. Consequently, the Seventh Circuit affirmed the district court's denial of Woodson's habeas petition. View "Woodson v Mlodzik" on Justia Law

Kurt Beathard, a football coach at Illinois State University (ISU), was terminated from his position as offensive coordinator after posting a handwritten message on his office door that read, "All Lives Matter to Our Lord & Savior Jesus Christ." This occurred during a period of tension and unrest on the ISU campus following the death of George Floyd. Beathard alleges that his termination was due to this personal speech, which he claims is protected by the First Amendment.In the District Court for the Central District of Illinois, Beathard filed a section 1983 action against Larry Lyons, the Athletic Director, and Brock Spack, the head football coach, asserting that his termination violated his First Amendment rights. The defendants moved to dismiss the complaint under Rule 12(b)(6), arguing that they were entitled to qualified immunity because it was not clear that Beathard's speech was protected as personal rather than official speech. The district court denied the motion to dismiss, stating that factual development was necessary before resolving the qualified immunity question.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court concluded that it lacked jurisdiction to hear the appeal because the district court had not made a definitive ruling on the qualified immunity defense but had instead postponed the decision, indicating that further factual development was needed. The Seventh Circuit emphasized that interlocutory orders, such as the denial of a motion to dismiss, are generally not immediately appealable unless they conclusively determine the disputed question. Consequently, the appeal was dismissed for want of appellate jurisdiction. View "Beathard v. Lyons" on Justia Law

David Paul Planchard was convicted by a jury of stalking Debra Doe and violating a protective order. Planchard and Doe had a relationship from 1997 to 2000 and had a son together in 2006. Despite a restraining order issued in 2020, Planchard continued to harass Doe through public Facebook posts from 2016 to 2023. These posts included threats, derogatory comments, and references to Doe's past trauma. Planchard also showed up at Doe's house in May 2023, violating the protective order.The Superior Court of Sacramento County found Planchard guilty of stalking and violating a protective order. The jury determined that Planchard's actions, including his Facebook posts and visit to Doe's house, constituted a credible threat and harassment. The court sentenced him to five years for stalking and a stayed term of six months for violating the protective order.The California Court of Appeal, Third Appellate District, reviewed the case. Planchard argued that his Facebook posts did not constitute direct contact and thus could not be considered harassment under the stalking statute. The court disagreed, citing precedent that indirect threats and harassment through third parties or public posts can still meet the statutory requirements for stalking. The court found sufficient evidence to support the jury's verdict, noting that the posts were intended to harass and threaten Doe, and it was reasonably foreseeable that she would see them.The court also addressed Planchard's claims of ineffective assistance of counsel, finding no merit in his arguments. The court concluded that the Facebook posts were relevant and admissible, and that any failure to object by his counsel did not constitute ineffective assistance. The judgment of the Superior Court was affirmed. View "P. v. Planchard" on Justia Law

Chanon Miller was arrested by deputies from the Palm Beach County Sheriff’s Office for simple battery against her ex-fiancé. She subsequently sued the Sheriff’s Office and unnamed deputies, alleging violations of her constitutional right to be free from unreasonable seizure, including claims of false arrest, false imprisonment, and malicious prosecution. Miller's complaint was amended to name specific deputies as defendants.The United States District Court for the Southern District of Florida denied the deputies' motion to dismiss based on qualified immunity, stating that the issue was more appropriately resolved at the summary judgment stage or later in the proceedings. The court found that Miller's allegations were sufficient to state a plausible claim for relief and allowed her to file an amended complaint naming the appropriate defendants. The district court reiterated its position when the deputies renewed their motion to dismiss after being named in the amended complaint.The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that the district court erred by failing to adjudicate the defense of qualified immunity at the motion to dismiss stage. The appellate court emphasized that qualified immunity is an immunity from suit, not just a defense to liability, and must be resolved at the earliest possible stage in litigation. The court vacated the district court’s order and remanded the case with instructions to rule on the deputies' entitlement to qualified immunity, requiring a claim-by-claim and defendant-by-defendant analysis. View "Miller v. Ramirez" on Justia Law

Christopher Kee was convicted of assault with a dangerous weapon in Indian country following an altercation with his then-girlfriend, Candace Chinchillas, in April 2020. The couple had a tumultuous relationship marked by excessive drinking and mutual accusations of abuse. Kee claimed that the stabbing incident was an act of self-defense, while Chinchillas described it as a violent attack. Kee was acquitted of three other counts of assault, which had more corroborative evidence, but was convicted on Count 2, which relied heavily on the conflicting testimonies of Kee and Chinchillas.The United States District Court for the District of New Mexico presided over Kee's trial. Kee did not object during the trial to the prosecution's use of his post-Miranda silence to impeach his testimony. After being convicted and sentenced, Kee filed a timely appeal, arguing that his due process rights were violated under Doyle v. Ohio, which prohibits the use of a defendant's post-Miranda silence for impeachment purposes.The United States Court of Appeals for the Tenth Circuit reviewed Kee's appeal. The court agreed with Kee that the prosecution's repeated references to his post-Miranda silence constituted a clear violation of Doyle. The court applied the plain error review standard, which requires showing that the error was plain, affected substantial rights, and seriously affected the fairness, integrity, or public reputation of judicial proceedings. The court found that the Doyle violation affected Kee's substantial rights because the case hinged on the credibility of Kee and Chinchillas, and the improper impeachment could have influenced the jury's verdict.The Tenth Circuit vacated Kee's conviction and sentence and remanded the case for further proceedings consistent with its opinion. View "United States v. Kee" on Justia Law

In the early morning of November 1, 2019, a group of law enforcement officers, including Task Force Officer (TFO) Clarence Belton and Charlotte-Mecklenburg Police Officer Heather Loveridge, attempted to execute a search warrant at the house of a suspect, Larry McConneyhead, in Charlotte, North Carolina. During the operation, McConneyhead fled into his house, and a confrontation ensued. TFO Belton was accidentally shot by Officer Loveridge, who mistook him for the suspect. Belton suffered severe injuries, leading to multiple surgeries and permanent disability.The case was initially filed in North Carolina state court and then removed to the United States District Court for the Western District of North Carolina. Belton alleged excessive force under 42 U.S.C. § 1983 and several state law claims against Officer Loveridge and the City of Charlotte. Officer Loveridge moved for summary judgment, asserting qualified immunity for the federal claim and public officers’ immunity for the state claims. The district court denied her motion, citing genuine disputes of material fact regarding the circumstances of the shooting.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that the district court failed to conduct the proper analysis for determining qualified immunity, which requires identifying the specific constitutional right violated and whether that right was clearly established at the time of the incident. The Fourth Circuit vacated the district court’s order and remanded the case for further proceedings, instructing the lower court to apply the correct legal standards for qualified immunity and public officers’ immunity. View "Belton v. Loveridge" on Justia Law

Dawn Lui, a longtime employee of the United States Postal Service (USPS), alleged disparate treatment, a hostile work environment, and unlawful retaliation under Title VII of the Civil Rights Act. Lui, a woman of Chinese ethnicity, claimed she was targeted with false complaints and grievances by employees at the Shelton Post Office due to her race, sex, and national origin. She was demoted from her position as Postmaster in Shelton, Washington, to a lower-paying Postmaster position in Roy, Washington, and replaced by a white man. Lui filed an informal discrimination complaint through USPS’s Equal Employment Opportunity (EEO) System and later a formal EEO complaint.The United States District Court for the Western District of Washington granted summary judgment to USPS on all of Lui’s claims. The court found that Lui failed to establish a prima facie case of discrimination, did not exhaust her administrative remedies for her hostile work environment claim, and failed to establish a causal connection for her retaliation claim.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court’s summary judgment on Lui’s disparate treatment claim, holding that Lui established a prima facie case of discrimination by showing she was replaced by a white man, which gave rise to an inference of discrimination. The court also found a genuine dispute of material fact about whether the decision to demote Lui was influenced by subordinate bias.The Ninth Circuit vacated the district court’s summary judgment on Lui’s hostile work environment claim, concluding that Lui exhausted her administrative remedies and remanded the case for the district court to address the merits of this claim. However, the court affirmed the district court’s grant of summary judgment on Lui’s retaliation claim, finding that Lui failed to establish a causal connection between her protected activity and the demotion. View "LUI V. DEJOY" on Justia Law

Dewey Austin Barnett, II, acting pro se, sued a Missouri county and a jail administrator, Brenda Short, alleging that they refused to allow him to have a Bible while he was in administrative segregation at the Jefferson County jail. Barnett claimed that the lack of a Bible caused him anxiety, stress, and depression, and led him to feel guilt and shame. He sought damages and injunctive relief. Barnett attached a grievance and a letter to his complaint, detailing his requests for a Bible and the jail's responses.The United States District Court for the Eastern District of Missouri dismissed Barnett's case. The court held that Barnett's RLUIPA claim could not succeed because RLUIPA does not permit plaintiffs to recover money damages, and his request for injunctive relief was moot due to his transfer to another facility. The court also dismissed Barnett's § 1983 claim, stating that he did not adequately plead Short's personal involvement in the decision to deprive him of his Bible and that the decision did not substantially burden his free exercise of religion. Additionally, the court dismissed the § 1983 claim against the county, explaining that Barnett failed to allege a policy of denying Bibles to inmates in administrative segregation.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed in part and reversed in part. The court held that RLUIPA permits claims for damages against the county, as "appropriate relief" includes damages. However, the court concluded that RLUIPA does not allow claims for damages against individuals in their personal capacities. The court also found that Barnett sufficiently alleged Short's personal involvement and that the deprivation of a Bible for a month substantially burdened his religious exercise. The court remanded the case for further proceedings on the RLUIPA claim against the county and the § 1983 claim against Short. View "Barnett v. Short" on Justia Law

Joel Uviles sued the City of New York under 42 U.S.C. § 1983, claiming that the New York City Department of Corrections (DOC) unlawfully detained him based on a state parole warrant. Uviles, who was on state parole, was arrested on new charges and detained without receiving a preliminary hearing within the required fifteen days. After posting bail on the new charges, he was still detained for another seventeen days until the state board of parole lifted the warrant.The United States District Court for the Eastern District of New York granted summary judgment in favor of the City. The court found that the City lawfully detained Uviles because the parole warrant was properly delivered to the New York City Police Department and the criminal court, and the warrant information was transmitted to the DOC. The court also held that the parole warrant remained facially valid even after the fifteen-day hearing deadline expired.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's judgment. The appellate court concluded that the City lawfully detained Uviles because the parole warrant was valid until it was lifted by the state board of parole or a court. The court held that the City had no discretion to release Uviles without such authorization, and therefore, his detention was lawful. The court also noted that the failure to provide a timely preliminary hearing did not render the warrant facially invalid under state law. View "Uviles v. City of New York" on Justia Law

In the early morning of October 23, 2013, Colleen Ritzer, a Danvers High School math teacher, was found dead in the woods outside the high school. She had been raped, strangled, and stabbed. The defendant, a fourteen-year-old student in her class, was convicted by a Superior Court jury of first-degree murder, aggravated rape, and armed robbery. The primary issue at trial was whether the defendant lacked criminal responsibility due to mental illness.The defendant appealed, arguing that the trial judge impeded his ability to present his defense. He raised several issues: the exclusion of expert testimony on brain scans, limitations on expert testimony regarding his statements, improper cross-examination of defense experts, forced disclosure of psychological test data, the use of suppressed statements by the Commonwealth's expert, the denial of a jury instruction on adolescent brain development, insufficient evidence for the aggravated rape and armed robbery convictions, the denial of a motion to suppress evidence, improper prosecutorial conduct in closing arguments, the denial of a change of venue due to pretrial publicity, and the proportionality of his sentence under the Massachusetts Declaration of Rights.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the convictions. The court held that the exclusion of the brain scan evidence was within the judge's discretion due to its limited probative value and potential for unfair prejudice. The limitations on expert testimony were also upheld, since the defendant was able to present sufficient evidence of his mental state. The court found no abuse of discretion in the cross-examination of defense experts or the disclosure of psychological test data. The use of the suppressed statements by the Commonwealth's expert did not warrant exclusion of the testimony. The court also found no error in the denial of the jury instruction on adolescent brain development, the sufficiency of the evidence for the aggravated rape and armed robbery convictions, the denial of the motion to suppress, or the prosecutor's closing arguments. The court concluded that the defendant was not entitled to a change of venue and that his sentence was not disproportionate under the Massachusetts Declaration of Rights. View "Commonwealth v. Chism" on Justia Law