Justia Civil Rights Opinion Summaries

L.C. Slaughter and Isiac Jackson were removed from their positions as commissioners of the Canton Municipal Utilities Commission by the City of Canton Board of Aldermen. They appealed their removal to the Madison County Circuit Court, arguing that their removal was illegal and violated their due process rights. The circuit court agreed, finding the removal void as a matter of law, and reinstated them to their positions. The Board appealed this decision.The Mississippi Supreme Court affirmed the circuit court's decision, holding that the Board's removal of Slaughter and Jackson without notice and an opportunity to be heard was improper. The Court issued its mandate on April 6, 2023, affirming their reinstatement. Subsequently, on April 27, 2023, Slaughter and Jackson filed a petition for back pay in the same circuit court case, seeking compensation for the period they were removed.The circuit court denied the petition for back pay, citing lack of jurisdiction, as the issue of back pay was not raised before the mandate was issued. Slaughter and Jackson appealed this denial. The Mississippi Supreme Court reviewed the case de novo and held that the circuit court lost jurisdiction once the appeal was filed and did not regain it after the Supreme Court's mandate, which did not remand any issues for further consideration. Consequently, the circuit court's denial of the petition for back pay was affirmed. View "Slaughter v. City of Canton, Mississippi" on Justia Law

Carter K. was scheduled to be released from jail in October 2022 when a mental health professional filed a petition for his hospitalization for evaluation. The superior court granted the petition, and Carter was transported to the Alaska Psychiatric Institute (API). API staff then filed petitions to commit Carter for 30 days of treatment and to administer medication. Carter waived his presence at the hearings, and his attorney appeared on his behalf. The State presented two witnesses: Carter’s primary provider at API, a nurse practitioner, and a court visitor.The nurse practitioner testified that Carter was diagnosed with schizophrenia and exhibited severe psychotic symptoms, including delusions and disorganized communication. He opined that Carter could not meet his basic needs if discharged. The court visitor corroborated this, noting Carter’s inability to make informed decisions about his treatment. The superior court master recommended Carter’s commitment for 30 days, finding him gravely disabled and unable to function independently. The master also recommended the administration of three medications: olanzapine, lorazepam, and diphenhydramine.The Supreme Court of the State of Alaska reviewed the case. Carter argued that the superior court erred in finding him gravely disabled and in approving the involuntary administration of medication. The Supreme Court held that the superior court did not plainly err in finding Carter gravely disabled, as the nurse practitioner’s uncontested testimony supported this conclusion. The court also found no less restrictive alternative to commitment was available, as outpatient treatment would not meet Carter’s needs.However, the Supreme Court found plain error in the order for the involuntary administration of lorazepam, as the superior court did not adequately consider the required factors to determine if it was in Carter’s best interests and if no less intrusive treatment was available. The commitment order and the medication order for olanzapine were affirmed, but the order for lorazepam was vacated. View "In the Matter of the Necessity for the Hospitalization of: Carter K." on Justia Law

In January 2015, Sarah Schoper, a tenure-track assistant professor at Western Illinois University, suffered a traumatic brain injury resulting in high-functioning mild aphasia and other physical disabilities. Despite her condition, she returned to teaching in May 2015, with accommodations from the University. Schoper applied for tenure in 2017 but was denied based on her teaching evaluations, which had declined post-injury. She then filed a lawsuit alleging disability discrimination and failure to accommodate under the Americans with Disabilities Act.The United States District Court for the Central District of Illinois granted summary judgment in favor of the University. The court found that Schoper could not prove that her disability was the but-for cause of her negative tenure recommendation. Additionally, the court ruled that Schoper failed to show how her requested accommodation—additional time to meet tenure criteria—would enable her to perform the essential functions of her job.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that Schoper was not a qualified individual under the ADA because her teaching evaluations did not meet the University's tenure requirements. The court also found that her request for more time to achieve tenure was not a reasonable accommodation, as it essentially sought a second chance rather than a modification to enable her to perform her job. Furthermore, the court concluded that no reasonable jury could find that Schoper's disability was the but-for cause of the University's decision to deny her tenure, given the multiple layers of review and the lack of evidence showing discriminatory intent by the reviewers. View "Schoper v. Board of Trustees of Western Illinois University" on Justia Law

The defendant was charged with unlawfully possessing a defaced firearm and unlawfully possessing a loaded firearm outside of his home or place of business. Before the trial, the prosecution filed a Sandoval application to cross-examine the defendant about his prior convictions and pending cases. The trial court held an in-camera conference on this motion without the defendant present. Later, in the defendant's presence, the court announced its decision on the Sandoval application without hearing arguments on the merits or confirming the defendant's understanding.The case proceeded to a bench trial where the prosecution presented evidence, including testimony from an arresting officer and surveillance footage. The trial court found the defendant guilty on both counts and sentenced him to imprisonment and post-release supervision. The Appellate Division affirmed the conviction, with one Justice dissenting on the grounds that the defendant was denied his right to be present during the Sandoval application consideration. The dissenting Justice granted the defendant leave to appeal.The New York Court of Appeals reviewed the case and held that the defendant's right to be present during a material stage of his prosecution was violated. The court found that the defendant had a right to be present at the initial in-chambers conference on the Sandoval application and that the subsequent in-court proceeding did not cure this violation. The court emphasized that the defendant's presence is crucial for meaningful participation in such hearings. Consequently, the Court of Appeals reversed the Appellate Division's order and granted the defendant a new trial. View "People v Sharp" on Justia Law

The case involves Roberto Cruz, who was convicted of two counts of indecent assault and battery on a child under the age of fourteen. The incidents occurred when Cruz, nearly sixty years old, hugged and kissed a thirteen-year-old girl, Jane, without her consent. Cruz was also charged with child enticement and simple assault and battery, but the latter charge was dismissed by the Commonwealth before the trial. The jury acquitted Cruz of child enticement and one count of indecent assault and battery but convicted him of the other two counts.Cruz appealed his convictions, arguing that the evidence was insufficient to prove the assaults were indecent. The Massachusetts Appeals Court agreed, reversing his convictions on the grounds that the conduct did not meet the statutory definition of indecent assault and battery. Following this reversal, Cruz filed a civil lawsuit seeking compensation for wrongful conviction under G. L. c. 258D. The Commonwealth moved for summary judgment, arguing that the reversal did not establish Cruz's innocence of the simple assault and battery charge, which had been dismissed earlier.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the eligibility for compensation under G. L. c. 258D is limited to felony convictions and does not include misdemeanors like simple assault and battery. Therefore, the court affirmed the Superior Court's denial of the Commonwealth's motion for summary judgment and remanded the case for further proceedings. The court concluded that Cruz met the eligibility requirements for compensation as the reversal of his felony convictions tended to establish his innocence of those charges. View "Cruz v. Commonwealth" on Justia Law

Thomas Eugene Creech, who has been on death row for over four decades for the 1981 murder of fellow inmate David Dale Jensen, filed a petition for a writ of mandamus. Creech alleged that the Ada County Prosecutor’s Office introduced fabricated or misleading evidence at his clemency hearing. He sought to recuse U.S. District Judge Amanda K. Brailsford from presiding over his underlying § 1983 suit, arguing that Judge Brailsford and Ada County Prosecutor Jan Bennetts are close friends, which could affect the judge's impartiality.The U.S. District Court for the District of Idaho denied Creech’s motion to preliminarily enjoin his execution, and the Ninth Circuit affirmed. Creech continued to litigate his § 1983 claim, alleging prosecutorial misconduct. He then moved to disqualify Judge Brailsford, citing her friendship with Bennetts. Judge Brailsford denied the recusal motion, stating that although she and Bennetts were close during their clerkship, they had since lost touch and a reasonable person would not question her impartiality.The United States Court of Appeals for the Ninth Circuit reviewed Creech’s petition for a writ of mandamus. The court found that the longstanding friendship between Judge Brailsford and Bennetts, combined with the allegations of prosecutorial misconduct involving Bennetts, could lead a reasonable person to question the judge’s impartiality. The court emphasized that public confidence in the judiciary requires that any appearance of bias be addressed promptly. Consequently, the Ninth Circuit granted the petition for a writ of mandamus and remanded the case for reassignment to a different judge. View "Creech v. United States District Court for the District of Idaho, Boise" on Justia Law

In February 2020, a police officer in Wauwatosa, Wisconsin, shot and killed a Black teenager, Alvin Cole. Following the incident, community members organized protests against police violence and racism. Anticipating unrest after the district attorney decided not to charge the officer, the mayor imposed a curfew. Plaintiffs, affected by the curfew and police conduct, filed constitutional and state law claims against the City of Wauwatosa and individual defendants.The United States District Court for the Eastern District of Wisconsin dismissed most claims, allowing only First Amendment and Driver’s Privacy Protection Act (DPPA) claims to proceed. The court later granted summary judgment for the defendants on the First Amendment claims, leaving only the DPPA claims for trial. The jury ultimately ruled in favor of the defendants on the DPPA claims.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the curfew was a permissible time, place, and manner restriction under the First Amendment. The court found that the curfew was content-neutral, served a significant government interest in public safety, was narrowly tailored, and left open ample alternative channels for communication. The court also upheld the dismissal of the plaintiffs' § 1983 claims against individual defendants, agreeing that the claims were inadequately pleaded and that the district court did not abuse its discretion in denying further amendments. Lastly, the court found no abuse of discretion in the district court’s response to a jury question regarding the definition of “personal information” under the DPPA. The judgment of the district court was affirmed. View "Knowlton v. City of Wauwatosa" on Justia Law

The case involves a probationer who was arrested during a traffic stop and subsequently charged with possession of cocaine with intent to distribute and unlawful possession of a firearm. During the traffic stop, a state trooper observed the vehicle speeding and making unsafe lane changes. Upon stopping the vehicle, the trooper noticed suspicious behavior from the back seat passenger and found drugs and a firearm in the vehicle. The probationer was found to have thrown a bag containing drugs to the back seat passenger as the vehicle was being pulled over.The Superior Court judge found the probationer in violation of his probation conditions, revoked his probation, and sentenced him to state prison. The probationer appealed, arguing that the evidence was insufficient to prove he possessed cocaine with intent to distribute and unlawfully possessed a firearm. He also claimed ineffective assistance of counsel for not moving to suppress the evidence on equal protection grounds, alleging racial animosity by the state trooper.The Supreme Judicial Court of Massachusetts reviewed the case and upheld the lower court's decision. The court found sufficient evidence to support the probation violation, including the possession and intent to distribute cocaine and the unlawful possession of a firearm. The court also rejected the claim of ineffective assistance of counsel, stating that the exclusionary rule does not generally apply to probation revocation proceedings and that the counsel's performance did not fall below the standard of an ordinary fallible lawyer.The court affirmed the revocation of probation and the denial of the motion for a new hearing. View "Commonwealth v. Gelin" on Justia Law

Lamonte Jackson-Gibson celebrated his birthday with friends, including his girlfriend, Toriel Dixon, in Detroit’s Greektown neighborhood. While listening to street musicians, Sergeant Reginald Beasley and other officers asked the group to move along. Jackson-Gibson questioned the order, leading to a verbal exchange and some physical pushing. Sgt. Beasley tased Jackson-Gibson in the back while he was embracing Dixon, and both were arrested. They were charged with obstructing or resisting a police officer, and Jackson-Gibson was also charged with disturbing the peace. A jury acquitted them of all charges.The United States District Court for the Eastern District of Michigan reviewed the case. Sgt. Beasley moved for summary judgment on the excessive-force claims, arguing for qualified immunity, but did not move for summary judgment on the wrongful-arrest claims. The district court granted summary judgment on Dixon’s excessive-force claim but denied it for Jackson-Gibson’s excessive-force claim. Sgt. Beasley’s motion to reconsider was also denied, leading to this interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Sgt. Beasley’s challenge to the wrongful-arrest claims for lack of jurisdiction, as he did not seek qualified immunity for those claims in the lower court. The court affirmed the district court’s denial of qualified immunity on Jackson-Gibson’s excessive-force claim. The court held that a reasonable jury could find that Sgt. Beasley’s use of a taser was objectively unreasonable, as Jackson-Gibson’s alleged crimes were not severe, he did not pose an immediate threat, and he was not actively resisting arrest. The court also held that the right to be free from excessive force when not actively resisting was clearly established by 2019. View "Jackson-Gibson v. Beasley" on Justia Law

The State of New York, through its Attorney General, sued the Niagara-Wheatfield Central School District, alleging that school officials failed to address repeated complaints of student-on-student sexual assault, harassment, and gender-based violence and bullying. The complaint detailed incidents involving four students who suffered from such misconduct and claimed that the school district ignored at least thirty similar incidents. The State argued that the school district's inaction affected not only the victims but also the broader school community, creating an unsafe environment.The United States District Court for the Western District of New York dismissed the case, concluding that the State lacked parens patriae standing. The court reasoned that the incidents were factually distinct and did not demonstrate a broader policy or practice of discrimination by the school district. Without such a policy or practice, the court held that the State could not show that the school district's conduct affected a substantial segment of the population, which is required for parens patriae standing.The United States Court of Appeals for the Second Circuit reviewed the case and reversed the district court's decision. The appellate court held that showing an injurious policy or practice is not necessary to satisfy the substantial-segment prong of the parens patriae standard. The court concluded that the State of New York had met its burden of pleading parens patriae standing at this stage of the litigation. The case was remanded for further proceedings consistent with the appellate court's opinion. View "New York v. Niagara-Wheatfield Central School District" on Justia Law