Justia Civil Rights Opinion Summaries

In 2016, James E. Moore, Jr., also known as Kevin Thompson, filed a lawsuit under 42 U.S.C. § 1983 against corrections officer Troy Booth and four other officers at Fishkill Correctional Facility, alleging excessive force. The officers, represented by the New York State Attorney General, claimed Thompson failed to exhaust administrative remedies as required by the Prison Litigation Reform Act (PLRA). In 2020, the Attorney General withdrew as Booth's counsel due to his non-participation. Booth subsequently failed to appear for a deposition and a pre-motion conference, leading the district court to strike his answer as a sanction. The district court dismissed the claims against the other officers for failure to exhaust administrative remedies but granted a default judgment against Booth, awarding $50,000 in damages.The United States District Court for the Southern District of New York dismissed the claims against the four other officers on the grounds that Thompson had not exhausted administrative remedies. However, it granted a default judgment against Booth because his answer, which included the exhaustion defense, had been struck due to his non-participation.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that the district court abused its discretion by granting a default judgment against Booth while dismissing the claims against the other officers on the merits. The appellate court held that, according to the principle set forth in Frow v. De La Vega, once the district court determined that Thompson could not maintain his claims against the litigating defendants due to failure to exhaust administrative remedies, it should have dismissed the claims against Booth for the same reason. The Second Circuit vacated the default judgment and remanded the case to the district court with instructions to enter a judgment in favor of Booth. View "Thompson v. Booth" on Justia Law

James Lamont Bagsby was convicted and sentenced to 107 years to life for violent crimes committed at age 15. After serving over 15 years, he petitioned for recall and resentencing under Penal Code section 1170(d), which applies to juveniles sentenced to life without parole. Bagsby argued his sentence was the functional equivalent of life without parole, citing People v. Heard, which held that denying such juveniles the opportunity to petition for resentencing violates equal protection. The trial court agreed, granted his petition, and ordered his release, but stayed the release pending appeal.The People appealed, asking the Court of Appeal to strike down the section 1170(d) resentencing provision or reconsider Heard. They also contended the trial court had jurisdiction to resentence Bagsby and erred by ordering his release. Bagsby cross-appealed the stay order.The California Court of Appeal, Fourth Appellate District, Division One, affirmed the trial court's orders. The court upheld Heard, finding no compelling reason to overturn it. The court rejected the People's arguments, noting that the Legislature had not repealed section 1170(d) despite amendments and that the trial court correctly applied Proposition 57 and Senate Bill 1391 retroactively, making Bagsby's judgment nonfinal and outside juvenile court jurisdiction. The court also found the stay order would expire upon remittitur, making Bagsby's release effective as of the original release date for custody credit purposes. View "P. v. Bagsby" on Justia Law

The case involves Jussie Smollett, who was initially indicted on 16 counts of felony disorderly conduct for allegedly falsely reporting a hate crime to the Chicago police. On March 26, 2019, the Cook County State’s Attorney’s Office (CCSAO) moved to dismiss the charges via nolle prosequi, citing Smollett’s community service and bond forfeiture as reasons. The trial court granted the motion, and Smollett’s bond was released to the City of Chicago.A retired appellate court justice later filed a motion to appoint a special prosecutor, questioning the resolution of the charges and the manner in which the Cook County State’s Attorney, Kim Foxx, had recused herself. Judge Michael Toomin appointed Dan Webb as special prosecutor, who then indicted Smollett on six counts of felony disorderly conduct. Smollett moved to dismiss the new indictment on double jeopardy grounds and argued that the appointment of the special prosecutor was invalid. The trial court denied these motions, and Smollett was convicted by a jury and sentenced to probation, jail time, a fine, and restitution.The Illinois Supreme Court reviewed the case and held that the second prosecution violated due process. The court found that the initial dismissal by nolle prosequi was part of a bilateral agreement between Smollett and the CCSAO, in which Smollett performed his part by forfeiting his bond and completing community service. The court ruled that the State must honor such agreements, and a second prosecution under these circumstances was fundamentally unfair and a due process violation. The court reversed Smollett’s conviction and remanded the case with directions to enter a judgment of dismissal. View "People v. Smollett" on Justia Law

Robert Mann, a taxpayer, filed a lawsuit against the State of California and the California Highway Patrol (CHP), challenging CHP’s vehicle impound policies. Mann argued that the impoundment of vehicles without a warrant and inadequate notice procedures constituted illegal expenditures of public funds. He sought declaratory and injunctive relief to prevent what he characterized as wasteful, unlawful, and unconstitutional law enforcement policies. The trial court granted a permanent injunction requiring CHP to consider vehicle owners’ ability to pay towing and storage fees during impound hearings and vehicle release procedures, and to revise its notice form to advise owners of procedures for retrieving impounded vehicles.The Superior Court of Los Angeles County initially reviewed the case. At the close of the plaintiffs’ case, the trial court granted a motion for judgment against Youth Justice Coalition and entered judgment in favor of defendant Warren A. Stanley, who had retired before the trial. The court found that Stanley, as a former public officer, was no longer a proper defendant. The trial court issued a permanent injunction requiring CHP to revise its vehicle impound procedures, including considering the ability to pay and revising notice forms.The Court of Appeal of the State of California, Second Appellate District, Division Two, reviewed the case. The court reversed the trial court’s judgment, holding that the injunction improperly required CHP to contravene valid statutes, relied on inapplicable case law, conflicted with the existing statutory scheme, and mandated unnecessary revisions to its notice procedures. The appellate court concluded that the trial court erred in requiring CHP to conduct ability-to-pay hearings and revise its notice forms, as these requirements were not mandated by due process and conflicted with statutory provisions. The judgment was reversed, and costs on appeal were awarded to the appellant. View "Mann v. State" on Justia Law

The defendant, Eliseo Martinez, restrained Nicasio Calixto Pascual while his cousin, Valente Martinez, stabbed Calixto 18 times. During an interview with detectives, Martinez admitted his participation in the stabbing. Martinez claimed the trial court improperly denied an instruction on voluntary manslaughter based on heat of passion, arguing it was not supported by the evidence and was prohibited under Penal Code section 192, subdivision (f)(1) due to the victim’s sexual orientation. Martinez also contended that his constitutional and statutory rights were violated when the court found him voluntarily absent from the trial.The Superior Court of Los Angeles County found Martinez guilty of attempted murder and determined several aggravating circumstances, including that the crime was a hate crime. Martinez was sentenced to 23 years in state prison. Martinez appealed, arguing the trial court erred in not instructing the jury on attempted voluntary manslaughter and in proceeding with the trial in his absence.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. The court held that the trial court correctly denied the instruction on voluntary manslaughter because there was no substantial evidence that Martinez acted in the heat of passion due to sufficient provocation. The court also found that Penal Code section 192, subdivision (f)(1) rendered any provocation related to the victim’s sexual orientation objectively unreasonable. Additionally, the court determined that substantial evidence supported the trial court’s finding that Martinez voluntarily absented himself from the trial, and thus, his right to be present was not violated. The judgment of the lower court was affirmed. View "P. v. Martinez" on Justia Law

Mica Martinez was convicted by an Oklahoma jury of two counts of first-degree murder and sentenced to death. Martinez sought federal habeas relief, arguing that his appellate counsel was ineffective for not raising a claim about his trial counsel’s inadequate investigation and presentation of testimony from his grandfather, mother, and uncle. He also claimed that his sentencing was fundamentally unfair due to witness testimony about his use of a racial slur and argued for reversible cumulative error.The Oklahoma Court of Criminal Appeals (OCCA) affirmed Martinez’s conviction and sentence, finding sufficient evidence of malice aforethought and holding that trial counsel did not perform deficiently. The OCCA also rejected Martinez’s claim that the introduction of a racial slur during sentencing denied him a fair proceeding, concluding that any error was cured by the trial court’s instruction to the jury to disregard the comment. The OCCA denied Martinez’s applications for postconviction relief, including his claim that appellate counsel was ineffective for not raising the issue of trial counsel’s investigation.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the denial of habeas relief. The court held that the OCCA did not unreasonably apply clearly established federal law or rely on an unreasonable factual finding in rejecting Martinez’s ineffective assistance of counsel claim. The court also found that Martinez failed to point to any clearly established federal law regarding the introduction of inflammatory evidence, and the OCCA did not base its decision on an unreasonable factual finding. Consequently, the court affirmed the denial of relief on the cumulative error claim as well. View "Martinez v. Quick" on Justia Law

A federal inmate, Dustin Rowland, developed a hernia after a pretrial detention fight. A physician deemed the hernia "reducible and stable," recommending non-surgical treatments. Rowland, desiring surgery, utilized the Bureau of Prisons' (BOP) Administrative Remedial Program, which involves a four-step grievance process. His initial requests were denied, but a later appeal led to approval for a surgical consultation. However, Rowland's final appeal was denied for procedural reasons, and he did not correct the deficiency. He eventually received surgery but filed a lawsuit claiming deliberate indifference to his medical needs, seeking damages under Bivens, injunctive relief for post-operative care, and a negligence claim under the Federal Tort Claims Act (FTCA).The United States District Court for the District of Colorado dismissed Rowland's Bivens claim, granted summary judgment against his injunctive relief claim for failure to exhaust administrative remedies, and dismissed the FTCA claim for lack of subject matter jurisdiction due to non-exhaustion. Rowland's motion for reconsideration was also denied.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's dismissal of the Bivens claim, noting that Rowland's case presented a new context not covered by previous Bivens cases and that the BOP's Administrative Remedial Program provided an adequate alternative remedy. The court also upheld the summary judgment on the injunctive relief claim, as Rowland failed to exhaust administrative remedies specifically for post-operative care. Lastly, the court affirmed the dismissal of the FTCA claim, emphasizing the jurisdictional requirement of exhausting administrative remedies before filing suit. The court found no abuse of discretion in the district court's denial of Rowland's Rule 60(b) motion for reconsideration. View "Rowland v. Matevousian" on Justia Law

Robert J. Hall, an inmate in the Missouri Department of Corrections (MDOC), filed a lawsuit against MDOC and Corrections Officer Paul Woodruff, in his individual capacity, for injuries he sustained from an attack by a fellow inmate, Ahmad Townsend. Hall had previously submitted an "Enemy Listing/Protective Custody Declaration" form indicating he felt threatened by Townsend. Despite this, Woodruff placed Townsend in Hall's cell while Hall was asleep, leading to the attack and resulting in mental and physical injuries.The United States District Court for the Western District of Missouri denied Woodruff’s motion to dismiss based on official immunity. Woodruff appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo, accepting all factual allegations as true and viewing them in the light most favorable to Hall. The court examined whether Woodruff was entitled to official immunity under Missouri state law, which protects public officials from liability for discretionary acts performed during their official duties. The court found that the MDOC policies cited by Hall did not create a ministerial duty because they allowed for discretion in how and when enemy declarations were checked and safeguards implemented.The Eighth Circuit concluded that Woodruff's actions were discretionary, not ministerial, and thus he was entitled to official immunity. The court reversed the district court's decision and remanded the case for further proceedings consistent with this opinion. View "Hall v. Woodruff" on Justia Law

Ngozi Iweha, a Black woman born and educated in Nigeria, was hired as a staff pharmacist at Larned State Hospital (LSH) in Kansas. She alleged that she faced a hostile work environment, disparate treatment, and retaliation in violation of Title VII. Incidents included exclusion from projects, insensitive comments about Nigeria, and a confrontation with a coworker involving "slave trade beads." She was eventually placed on administrative leave and terminated following an investigation into her workplace conduct.The United States District Court for the District of Kansas granted summary judgment in favor of the defendants. The court found that the incidents described by Iweha did not amount to a hostile work environment as they were not sufficiently severe or pervasive. The court also determined that Iweha failed to show that her termination was pretextual. The court noted that the employer's progressive discipline policy was discretionary and that the investigation into Iweha's conduct was independent and thorough. Additionally, the court found that Iweha did not establish a prima facie case of retaliation, as her complaints did not specifically allege discrimination based on race or national origin.The United States Court of Appeals for the Tenth Circuit affirmed the district court's judgment. The appellate court agreed that the incidents described by Iweha were not severe or pervasive enough to create a hostile work environment. The court also found that Iweha failed to demonstrate that the reasons for her termination were pretextual. The court noted that the investigation into her conduct was independent and that the decision to terminate her was based on legitimate, non-discriminatory reasons. The court also upheld the finding that Iweha did not establish a prima facie case of retaliation. View "Iweha v. State of Kansas" on Justia Law

Horace Crump, an inmate at Lakeland Correctional Facility in Michigan, filed a § 1983 lawsuit against several prison employees, alleging they withheld treatment for his multiple sclerosis. The key issue at this stage is whether Crump can proceed with his lawsuit without paying the filing fee upfront, as he sought to proceed in forma pauperis due to his inability to pay.The United States District Court for the Western District of Michigan dismissed Crump's complaint, citing the Prison Litigation Reform Act's three-strikes rule, which disqualifies prisoners from proceeding in forma pauperis if they have had three or more prior actions or appeals dismissed as frivolous, malicious, or for failing to state a claim. Crump appealed, disputing two of the three strikes counted against him.The United States Court of Appeals for the Sixth Circuit reviewed the case and focused on whether Crump's prior dismissals counted as strikes under the Act. The court found that Crump's previous cases, which included dismissals for failure to state a claim and decisions not to exercise supplemental jurisdiction over state-law claims, did not count as strikes. The court reasoned that the Act's language refers to entire actions being dismissed on specific grounds, not individual claims. Additionally, dismissals based on Eleventh Amendment immunity do not count as strikes under the Act.The Sixth Circuit vacated the district court's judgment and remanded the case for further proceedings, allowing Crump's lawsuit to proceed without the upfront payment of the filing fee. View "Crump v. Blue" on Justia Law