Justia Civil Rights Opinion Summaries

Fourteen civilly committed clients of the Minnesota Sex Offender Program (MSOP) filed a lawsuit challenging MSOP policies that affected their spiritual group activities, particularly those impacted by the COVID-19 pandemic. Before the pandemic, MSOP allowed clients to participate in spiritual groups under certain conditions. However, during the pandemic, MSOP implemented new regulations that restricted these activities. Plaintiffs argued that these restrictions violated the U.S. Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the District of Minnesota granted summary judgment in favor of the defendants, finding that the plaintiffs' claims were moot because the COVID-19 restrictions had been lifted, and pre-pandemic policies were reinstated. The court also declined to address new concerns raised by the plaintiffs regarding MSOP's current policies, as these issues were not included in the second amended complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims about the pandemic-era policies were moot since those policies were no longer in effect. The court also found that the plaintiffs' new concerns about MSOP's current policies were not properly pled in the second amended complaint and thus were not before the court. Additionally, the appellate court denied the plaintiffs' motion to supplement the record with discovery documents, as the plaintiffs failed to provide a valid reason for not including these documents earlier, and their inclusion would not change the case's resolution. View "Allan v. Minnesota DHS" on Justia Law

The case involves a challenge to the constitutionality of 18 U.S.C. §§ 922(b)(1) and (c)(1), which prohibit Federal Firearms Licensees (FFLs) from selling handguns to individuals aged eighteen to twenty. The plaintiffs, including individuals in this age group and several nonprofit organizations, argue that these provisions infringe on their Second Amendment rights and deny them equal protection under the Fifth Amendment.The United States District Court for the Western District of Louisiana found that the plaintiffs had standing but dismissed the case under Rule 12(b)(6). The district court assumed that the Second Amendment's plain text covered the purchase of firearms by eighteen-to-twenty-year-olds but concluded that the prohibition was consistent with the nation's historical tradition of firearm regulation, relying on the framework established by the Supreme Court in New York Rifle & Pistol Ass’n, Inc. v. Bruen.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the Second Amendment does cover the right of eighteen-to-twenty-year-olds to purchase firearms. The court found that the historical evidence presented by the government, including 19th-century laws, was insufficient to establish a tradition of restricting firearm rights for this age group in a manner similar to the contemporary federal handgun purchase ban. The court emphasized that the Second Amendment's protections extend to all law-abiding, adult citizens, including those aged eighteen to twenty.The Fifth Circuit held that 18 U.S.C. §§ 922(b)(1) and (c)(1) and their attendant regulations are unconstitutional as they are inconsistent with the nation's historical tradition of firearm regulation. The court reversed the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Reese v. Bureau of Alcohol, Tobacco, Firearms, and Explosives" on Justia Law

Sherran Wasserman agreed to sell land in Franklin County to Anthony Pham, contingent on the approval of a conditional use permit by the Franklin County Board of Commissioners. Pham applied for the permit to build and operate chicken houses, but the Board denied the application. Wasserman then sued the Board and the County, initially bringing multiple claims under state and federal law. She dismissed some claims, conceded others, and the trial court dismissed her remaining state-law claims due to sovereign immunity. This left two federal claims: one alleging the County violated Pham’s equal protection rights based on race, and another alleging a violation of Wasserman’s equal protection rights as a “class of one.”The trial court denied the County’s motion for summary judgment, applying the federal doctrine of third-party standing, which allows a plaintiff to assert the rights of third parties. The court found genuine issues of material fact precluded summary judgment on standing and the merits of Wasserman’s equal protection claims. The Court of Appeals reversed, concluding Wasserman lacked third-party standing and that her “class of one” claim failed as a matter of law.The Supreme Court of Georgia reviewed whether a plaintiff may rely on the federal doctrine of third-party standing to establish constitutional standing in Georgia courts. The court held that Georgia’s constitutional standing requirements, rooted in the common law and consistent precedent, do not allow a plaintiff to maintain an action by asserting only the rights of a nonparty. The court overruled its previous adoption of the federal doctrine of third-party standing, concluding that a plaintiff must assert her own legal rights to invoke the judicial power of Georgia courts. The judgment was vacated and remanded for further proceedings consistent with this opinion. View "WASSERMAN v. FRANKLIN COUNTY" on Justia Law

Curtis Wells parked his car near Arlington Cemetery and was noticed by Officer Armstrong due to his animated gestures while on a phone call. Armstrong approached Wells and discovered that his car had an expired registration. Arlington County police were called, and they found that Wells did not have a driver's license and had weapons in his car. The police decided to tow Wells's car and conducted an inventory search, which revealed various weapons and tactical gear, including a ballistic plate carrier. Wells was sent home, but further investigation suggested that the plate might have been stolen from the Army. Nine days later, Wells was arrested for receiving stolen property.In the United States District Court for the Eastern District of Virginia, Wells brought state and federal claims against various officers and entities, alleging Fourth and Fifth Amendment violations, among other claims. The district court dismissed all his claims, reasoning that the officers were protected by qualified immunity and that Wells had not plausibly alleged the necessary elements for his state tort claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the officers' actions were protected by qualified immunity because Wells did not have a clearly established right against the officers' conduct. The court found that the initial approach by Officer Armstrong was justified under the community-caretaking exception, the inventory search of Wells's car was conducted according to standard procedures, and Wells had consented to the safekeeping of his property. Additionally, the court held that Wells's Second Amendment claims failed because the right to public carry was not clearly established in 2020. The court also dismissed Wells's state law claims, finding that he had not plausibly alleged the necessary elements for false imprisonment or malicious prosecution. View "Wells v. Fuentes" on Justia Law

A pretrial detainee at Goose Creek Correctional Center was asked to provide a urine sample for random drug testing. Under the Department of Corrections (DOC) policy, inmates have two hours to provide a sample. The detainee attempted to comply but was unable to urinate within the required time. Consequently, he was charged with refusing to provide a urine sample, which is considered a high-moderate infraction, and was disciplined.The detainee pled not guilty at a disciplinary hearing, arguing that he tried to comply but could not urinate. The prison tribunal found him guilty using the preponderance of the evidence standard and imposed punitive segregation. The detainee appealed to the facility’s superintendent, who upheld the decision. He then appealed to the superior court, arguing that the preponderance of the evidence standard violated his due process rights and that he should have been offered a saliva test instead of a urine test.The superior court affirmed the administrative decision, concluding that the preponderance of the evidence standard is constitutional. The court also noted that the detainee did not raise the saliva test argument until his reply brief, thus it was not preserved for review.The Supreme Court of the State of Alaska reviewed the case. The court held that the Alaska Constitution permits the use of a preponderance of the evidence standard in prison disciplinary proceedings, balancing the inmate’s interest in avoiding harsher conditions against the prison’s interest in maintaining order. The court also declined to address the saliva test argument, as it was not properly preserved during the administrative proceedings or raised in a timely manner in the superior court. The decision of the superior court was affirmed. View "Valoaga v. State of Alaska" on Justia Law

Marcus Todd, a state employee in Minnesota, alleged that a union violated his First and Fourteenth Amendment rights by deducting union dues from his paycheck without his consent. Todd joined the American Federation of State, County, and Municipal Employees in 2014 and authorized dues deductions. In 2018, a new authorization card was allegedly signed electronically with Todd's name, which he claims was forged. After the Supreme Court's decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, Todd attempted to resign from the union and stop dues deductions, but the union continued until May 2021, citing an annual opt-out period.The United States District Court for the District of Minnesota dismissed Todd's federal claims, stating that he voluntarily agreed to the dues deductions before Janus and was contractually bound to the opt-out period. The court also found that the union did not act under color of state law regarding the alleged forgery and dismissed Todd's claims for prospective relief as moot. The court declined to exercise jurisdiction over Todd's state law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Todd's claims failed due to the lack of state action, as the union's actions were based on private agreements, not state statutes. The court referenced Hoekman v. Education Minnesota and Burns v. School Service Employees Union Local 284, which established that private agreements for dues deductions do not constitute state action. The court also found that the alleged forgery did not establish state action, as it was a private misuse of state law. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Todd v. AFSCME" on Justia Law

Justin and Jared Brackett own and operate two restaurants in Harwich, Massachusetts: Ember Pizza, Inc. and The Port Restaurant and Bar, Inc. Both establishments held liquor and entertainment licenses issued by the town. Allegedly, they violated Harwich's noise ordinance and Massachusetts COVID-19 restrictions, leading to suspensions and restrictions on their permits. In response, they sued Harwich, several town officials, and other individuals in federal district court, asserting various federal and state claims.The United States District Court for the District of Massachusetts largely granted the defendants' dispositive motions, rejecting all of Ember and The Port's claims. The court also denied their request for leave to amend their complaint, finding that an amendment would be futile. Ember and The Port then appealed the district court's decisions.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's rulings. The appellate court held that Ember and The Port failed to state a plausible claim for relief under federal law, including their First Amendment, Fourteenth Amendment, and procedural due process claims. The court also found that the Massachusetts Civil Rights Act claims and common law claims, including civil conspiracy and defamation, were inadequately pleaded. The court concluded that the district court did not abuse its discretion in denying the request for leave to amend the complaint, as the proposed amendments would not have cured the deficiencies in the original complaint. View "3137, LLC v. Town of Harwich" on Justia Law

Johnnie Franklin Wills, a state prisoner, filed a habeas petition challenging his life sentence under West Virginia’s recidivist statute. He argued that the judicially crafted test for determining whether a recidivist life sentence is proportional to the crime is unconstitutionally vague. Wills was convicted of grand larceny and conspiracy to commit grand larceny in 2016, and due to his prior eight felony convictions, he was sentenced to life imprisonment with parole eligibility after fifteen years under the recidivist statute.The West Virginia courts denied Wills relief, stating that the void-for-vagueness doctrine does not apply to their proportionality test. The Supreme Court of Appeals of West Virginia affirmed this decision, distinguishing Wills’s case from the U.S. Supreme Court’s decisions in Johnson v. United States and Sessions v. Dimaya, which invalidated certain statutory provisions as unconstitutionally vague. The state court maintained that the proportionality test was clear and did not fall under the same scrutiny as the statutes in Johnson and Dimaya.Wills then filed a federal habeas petition under 28 U.S.C. § 2254, which the United States District Court for the Northern District of West Virginia also denied. The district court found that the state court’s decision was not contrary to or an unreasonable application of clearly established federal law. The court noted that the proportionality test serves as a judicial limitation on the recidivist statute, unlike the statutory mandates in Johnson and Dimaya.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The court held that the state court’s ruling was not an unreasonable application of clearly established federal law, as the U.S. Supreme Court has not extended the void-for-vagueness doctrine to judicially crafted proportionality tests. Therefore, Wills’s habeas petition was denied. View "Wills v. Pszczolkowski" on Justia Law

In the early hours of May 11, 2018, Chasrick Heredia, while celebrating his birthday, had a violent encounter with Manchester Police officers, including Officer Michael Roscoe. Heredia filed a complaint alleging excessive force and other constitutional violations. At trial, the jury found Roscoe liable for excessive force and awarded Heredia nominal and punitive damages. The district court denied Roscoe's motions for judgment as a matter of law (JMOL) and for remittitur of the punitive damages award.The United States District Court for the District of New Hampshire presided over the initial trial. The jury found in favor of Heredia on the excessive force claim against Roscoe but in favor of the defendants on all other claims. Roscoe's post-trial motions for JMOL and remittitur were denied by the district court, which concluded that a reasonable juror could find that Roscoe violated Heredia's constitutional rights and that qualified immunity did not apply.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's denial of Roscoe's motions. The appellate court held that a reasonable jury could find that Roscoe used excessive force when he performed a takedown on Heredia after Heredia had submitted to arrest by raising his hands. The court also held that Roscoe was not entitled to qualified immunity because it was clearly established that increasing the use of force after an arrestee had submitted was unconstitutional. Additionally, the court found that the punitive damages awarded were justified based on Roscoe's reckless indifference to Heredia's constitutional rights. View "Heredia v. Roscoe" 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 this disparity violated equal protection principles.The California Court of Appeal, Fourth Appellate District, previously found merit in Field's equal protection argument 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 determined that the People had not met their burden to justify the disparate treatment of SVPs and NGIs. Consequently, the court concluded that equal protection principles were violated and ordered new commitment trials for both Field and Asher.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 equal protection violation was not justified. View "P. v. Field" on Justia Law