Justia Civil Rights Opinion Summaries

Jeannine Bedard, a Los Angeles Police Department (LAPD) officer, refused to comply with the City of Los Angeles’s COVID-19 vaccination mandate and did not sign a notice enforcing the mandate. Consequently, the Chief of Police sought to terminate her employment. The LAPD Board of Rights reviewed the proposed discipline, found Bedard guilty of failing to comply with conditions of employment, and upheld her discharge. The Board also found that the City violated Bedard’s due process rights by not providing sufficient time to respond to the charges and awarded her back pay, which the City did not pay.Bedard filed a petition for a writ of mandate in the Superior Court of Los Angeles County, arguing that the disciplinary action was procedurally and legally invalid and seeking reinstatement and back pay. The trial court found the termination justified but agreed that the City violated Bedard’s due process rights by giving her insufficient time to respond. The court awarded her back pay.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. Bedard argued that her termination was improper because it was based on her refusal to sign an allegedly illegal contract, was too harsh a penalty, and violated her due process rights under Skelly v. State Personnel Board. The appellate court affirmed the trial court’s decision, holding that Bedard’s refusal to comply with the vaccination mandate justified her termination. The court found substantial evidence supporting the trial court’s conclusion that Bedard’s termination was not solely based on her refusal to sign the notice but also on her refusal to comply with the vaccination requirement. The court also held that the appropriate remedy for the due process violation was back pay, not reinstatement. View "Bedard v. City of Los Angeles" on Justia Law

Marcus McVae was stopped by Texas State Trooper Jesse Perez for a traffic violation. McVae provided a false identity and fled on foot when the officer attempted to detain him. Despite being tased, McVae continued to flee, leading to a physical altercation with Trooper Perez. During the struggle, McVae threw a rock at Perez, who then fatally shot McVae. McVae’s parents sued Perez under 42 U.S.C. § 1983, claiming excessive force in violation of the Fourth Amendment.The United States District Court for the Western District of Texas granted summary judgment in favor of Trooper Perez, finding that he was entitled to qualified immunity. The court relied on body camera footage to support its decision, concluding that no genuine dispute of material fact existed regarding whether McVae posed an immediate threat to Perez.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that Trooper Perez’s use of deadly force was reasonable under the circumstances. The court found that McVae’s actions, including throwing a rock at Perez, constituted a severe threat, justifying the use of deadly force. The court concluded that Perez did not violate McVae’s Fourth Amendment rights and was entitled to qualified immunity. View "McVae v. Perez" on Justia Law

In this case, Jimmy Davis, Jr., an Alabama prisoner sentenced to death for the 1993 murder of Johnny Hazle during a gas station robbery, appealed the district court’s denial of his 28 U.S.C. § 2254 federal habeas petition. Davis argued that his trial counsel was ineffective during the penalty phase of his trial for failing to investigate and present mitigating evidence of childhood abuse and the circumstances of his prior conviction for third-degree robbery.The Alabama Court of Criminal Appeals affirmed Davis’s conviction and sentence on direct appeal. Davis then filed a state postconviction petition, which was denied after an evidentiary hearing. The state court found that Davis’s trial counsel did not perform deficiently and that Davis was not prejudiced by the alleged deficiencies. The Alabama Court of Criminal Appeals affirmed the denial of the postconviction petition, concluding that the investigation conducted by Davis’s attorneys was reasonable and that Davis failed to show prejudice.The United States District Court for the Northern District of Alabama denied Davis’s § 2254 petition, concluding that the state court’s decision was not an unreasonable application of Supreme Court precedent or based on an unreasonable determination of the facts. The Eleventh Circuit Court of Appeals reviewed the case and affirmed the district court’s denial of the habeas petition.The Eleventh Circuit held that the state court’s conclusion that Davis was not prejudiced by his counsel’s alleged deficiencies was not contrary to or an unreasonable application of clearly established federal law. The court noted that the additional mitigating evidence presented during the postconviction proceedings, including evidence of childhood abuse and the non-violent nature of the prior robbery, did not create a reasonable probability of a different outcome. The court emphasized that the state court’s decision was not so obviously wrong that it lay beyond any possibility for fairminded disagreement. View "Davis v. Commissioner, Alabama Department of Corrections" on Justia Law

A transgender woman, who had legally changed her name and gender marker in 2018, sought to have the entire record of her name change and gender marker correction sealed in 2023. She argued that the public availability of these records had led to harassment and threats after her transgender status was disclosed on social media, revealing her personal information and former name. The trial court denied her request to seal the entire record but did seal her application to seal, its supporting documentation, and a physician’s letter attached to her initial petition.The Superior Court of Stanislaus County initially granted her petition for a name and gender change in 2018 without any objections. In 2023, she filed an application to seal the entire record, citing harassment and threats due to the public availability of her records. The trial court denied the request to seal the entire record, reasoning that there was no evidence the harassment was initiated by the court’s records and that sealing the records would not necessarily solve the problem. The court also noted the strong presumption that name changes be public to prevent fraud and ensure creditors and others can locate individuals who have changed their names.The California Court of Appeal, Fifth Appellate District, reviewed the case and found that the trial court’s findings were not supported by substantial evidence. The appellate court concluded that the appellant’s privacy and safety interests in concealing her transgender identity outweighed the public’s right of access to the records. The court held that the entire record should be sealed to protect her privacy and safety, as there was no less restrictive means to achieve these interests. The appellate court reversed the trial court’s order and remanded the case with instructions to seal all records revealing the appellant’s name change or gender marker correction. View "In re M.T." on Justia Law

Khyle Armando Briscoe, a youth offender, was sentenced to life without parole for a special circumstance murder committed when he was 21. The murder occurred during a robbery where Briscoe and an accomplice, Shaun P., attacked an acquaintance, Ben P. During the struggle, Ben P. managed to take Briscoe’s gun and fatally shot Shaun P. Briscoe was convicted of first-degree murder, robbery, and burglary, with the jury finding true the special circumstance that he acted with reckless indifference to human life and was a major participant in the underlying felonies.The trial court sentenced Briscoe to life without parole, and the conviction was affirmed on appeal. Briscoe later filed a motion for a parole hearing under Penal Code section 3051, which grants certain youth offenders the opportunity to seek parole but excludes those sentenced to life without parole. The trial court denied his motion, and Briscoe appealed.The California Court of Appeal, First Appellate District, reviewed the case. The court found that section 3051’s exclusion of youth offenders sentenced under section 190.2, subdivision (d) for special circumstance murder, while including those convicted of first-degree felony murder under section 189, subdivision (e)(3), violated equal protection. Both statutes employ the same standard of liability, and the underlying felonies were the same. The court held that there was no rational basis for treating these offenders differently under section 3051.The court reversed the trial court’s order denying Briscoe a section 3051 hearing and remanded the case for the trial court to conduct a Franklin proceeding and a parole hearing. The court reformed section 3051 to include youth offenders like Briscoe, who were sentenced to life without parole under section 190.2, subdivision (d) for murder during a robbery or burglary. View "P. v. Briscoe" on Justia Law

Two defendants, Martin Field and John Asher, were found to be sexually violent predators (SVPs) by separate juries and committed indefinitely to a state hospital. They were compelled to testify against themselves during their commitment trials. Both argued on appeal that they were similarly situated to individuals found not guilty by reason of insanity (NGIs), who are not required to testify against themselves at their commitment trials. They claimed that this disparity violated equal protection principles.The California Court of Appeal, Fourth Appellate District, had previously determined that Field’s equal protection argument had merit and remanded the case to the Superior Court of San Bernardino County for an evidentiary hearing. The same conclusion was reached for Asher’s case by Division Three of the Fourth Appellate District. The trial court held an evidentiary hearing and found that the People had not satisfied their burden to justify the disparate treatment of SVPs and NGIs. Consequently, the court concluded that equal protection principles were violated by requiring Field and Asher to testify during their commitment trials and ordered new commitment trials for both.The People appealed the new trial orders, arguing that the trial court erred in finding that the disparate treatment of SVPs was not justified. The California Court of Appeal, Fourth Appellate District, reviewed the case and affirmed the trial court’s orders. The appellate court held that the People had not demonstrated that the testimony of SVPs was more necessary than that of NGIs to justify the disparate treatment under the strict scrutiny standard. The court emphasized that there were sufficient records and other means to evaluate SVPs without compelling their testimony, and thus, the orders for new trials were affirmed. View "P. v. Field" on Justia Law

Several contractors and an employee, who regularly handle public works projects for PennDOT and SEPTA, challenged Philadelphia's requirement for project labor agreements (PLAs) on public projects. These PLAs mandated union recognition and membership, and set workforce diversity goals. The plaintiffs argued that these requirements violated their First Amendment rights and the Equal Protection Clause, as well as 42 U.S.C. § 1981. They were ineligible to bid on certain city projects due to their existing collective bargaining agreements with the United Steelworkers, which is not affiliated with the required unions.The United States District Court for the Eastern District of Pennsylvania granted summary judgment to Philadelphia. The court found that the plaintiffs lacked standing to challenge the union-eligibility requirement and failed to show that the diversity requirement caused them harm based on race. The court also concluded that the plaintiffs' § 1981 claim failed because race was not a but-for cause of their inability to work on city projects with PLAs.The United States Court of Appeals for the Third Circuit reviewed the case and found that the plaintiffs had standing to challenge the union-eligibility requirement under the First Amendment. The court determined that the plaintiffs suffered a concrete and particularized injury by being ineligible to bid on city projects due to the PLAs. The court also found that the plaintiffs' claims were not moot despite Philadelphia's subsequent changes to the PLAs, as the plaintiffs sought damages for past violations and prospective relief.The Third Circuit also found that the plaintiffs had standing to raise an Equal Protection claim, as they demonstrated an intent to bid on future projects covered by the PLAs. The court vacated the District Court's judgment and remanded the case for further proceedings to consider the merits of the plaintiffs' First Amendment, Equal Protection Clause, and § 1981 claims. View "Road-Con Inc v. City of Philadelphia" on Justia Law

Three practicing Muslim men alleged that federal agents asked them to serve as informants in Muslim communities. When they refused, the agents placed or retained them on the "No Fly List" and suggested they could be removed from the list if they agreed to work as informants. The plaintiffs sought damages under the Religious Freedom Restoration Act (RFRA), claiming that their religious beliefs precluded them from serving as informants and that the agents substantially burdened their exercise of religion by conditioning their removal from the No Fly List on actions that violated those beliefs.The United States District Court for the Southern District of New York dismissed the complaint on qualified immunity grounds, concluding that the agents were entitled to qualified immunity because there was no clearly established right not to be pressured to inform on members of one's religious community through the coercive or retaliatory use of the No Fly List.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The court held that the agents were entitled to qualified immunity because a reasonable person in their position would not have understood that their conduct implicated the plaintiffs' religious beliefs. The court noted that the plaintiffs did not disclose their religious objections to the agents, and there were no facts plausibly supporting the conclusion that the agents knew the plaintiffs' objections were grounded in their religious beliefs. Therefore, the agents were entitled to qualified immunity from damages in their personal capacities. View "Tanvir v. Tanzin" on Justia Law

In 2002, Natale Cosenza was convicted by a Massachusetts state court jury of assault and battery with a dangerous weapon and armed burglary. The prosecution's case heavily relied on the victim, Melissa Horgan, identifying Cosenza from a photo array administered by Worcester police. In 2016, state courts granted Cosenza a new trial, and in 2017, they suppressed the photo array evidence, leading the Commonwealth to drop the charges.Cosenza then filed a federal civil rights lawsuit in 2018 against the City of Worcester, alleging that the City had a policy of not properly training its officers on photo arrays and other investigative techniques, which he claimed violated his constitutional rights. The U.S. District Court for the District of Massachusetts granted summary judgment in favor of the City, finding no evidence of deliberate indifference to Cosenza's constitutional rights.The United States Court of Appeals for the First Circuit reviewed the case. The court found that there was no evidence Worcester had a policy of not training its officers on photo arrays. The court noted that officers received training at a police academy and on-the-job training, and that the law at the time did not clearly establish the procedures Cosenza argued were required. The court also found no evidence that the City had a policy of fabricating or suppressing evidence. Consequently, the First Circuit affirmed the district court's summary judgment in favor of the City of Worcester. View "Cosenza v. City of Worcester, MA" on Justia Law

Ali Naji entered the Dearborn police station, pointed a gun at Corporal Timothy Clive, and attempted to shoot him. The gun malfunctioned, and while Naji tried to fix it, Clive shot and killed him. Hussein Naji, representing Ali Naji's estate, sued Clive and the City of Dearborn under 42 U.S.C. § 1983 for excessive force and state tort claims. The district court granted summary judgment in favor of Clive and the City on all claims.The United States District Court for the Eastern District of Michigan found that Clive's use of deadly force was objectively reasonable under the circumstances. Naji had pointed a gun at Clive and attempted to fire, posing an immediate threat. The court also noted that Clive was behind bulletproof glass and that the incident occurred in a busy police station. The court dismissed the claims against the City of Dearborn, as there was no underlying constitutional violation to support municipal liability.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that Clive's actions were objectively reasonable and that he had probable cause to believe Naji posed an immediate threat. The court also rejected the argument that Naji's mental illness should have altered the assessment of the threat. Additionally, the court found that Clive was entitled to qualified immunity and that the City of Dearborn could not be held liable without an underlying constitutional violation.The court also addressed the state law claims, finding that Clive acted in good faith and was immune from assault and battery claims under Michigan law. The court dismissed the gross negligence claim, noting that it was essentially an excessive force claim in disguise and that Naji's representative failed to establish a legal duty for Clive to follow internal departmental policies. The court affirmed the district court's grant of summary judgment in favor of Clive and the City of Dearborn. View "Naji v. City of Dearborn, Michigan" on Justia Law