Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgments of the district courts denying Appellants' separate motions to suppress, holding that the Wyoming Constitution does not require that an exterior canine sniff of a vehicle be supported by probable cause.Appellants in these cases were both subjected to an extended investigative detention, and both Appellants were arrested after a canine sniff of their vehicles. On appeal, Appellants argued that the canine sniffs had to be supported by probable cause under Wyo. Const. art. I, 4. The Supreme Court disagreed, holding (1) the Wyoming Constitution does not require probable cause for an exterior canine sniff of a vehicle; and (2) Appellants were not entitled to relief on their remaining allegations of error. View "Tarzia v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that a trial court can properly consider conduct related to a charge of which a criminal defendant was acquitted when the court sentences the defendant on other charges of which the defendant was convicted but that courts should be extremely cautious in relying on such conduct in sentencing.Defendant was convicted and sentenced for robbery in the first degree and other offenses. Defendant later filed his motion to correct an illegal sentence arguing that the sentencing court violated his constitutional rights by considering conduct underlying a charge for which he was acquitted - assault. The trial court denied the motion. The Supreme Court affirmed, holding (1) a sentencing judge may consider a broad range of conduct so long as the sentence falls within the statutory range and the conduct does not serve as grounds to enhance the sentence; and (2) the sentencing court in this case did not violate Defendant's right to trial by jury under the Sixth Amendment or his right to due process under the Fourteenth Amendment by considering the conduct underlying his assault charge. View "State v. Langston" on Justia Law

While an Illinois State Police (ISP) lieutenant, Dunn was assigned to the Illinois Gaming Board. According to ISP, federal agents informed the ISP that he was implicated in a federal criminal investigation into mortgage fraud. In 2014, the ISP placed him on restricted duty. ISP records reflected that Dunn was the “subject of a federal criminal felony investigation.” Dunn admits that he participated in a voluntary interview with federal investigators, but denies that he was under investigation. He claims that the ISP was never told that he was a “target.” According to ISP, it “could not obtain any additional documentation” before placing Dunn on restricted duty because of “limitations with federal grand jury regulations.” In 2016, Dunn filed suit, 42 U.S.C. 1983, against three individuals in their personal and official capacities, alleging that they had violated his right to due process without opportunity for a hearing by depriving him of a liberty interest in future occupational opportunities. He asserted that the defendants had notified third parties that ISP had stripped him of his law-enforcement authority. While the lawsuit was pending, Dunn retired while on restricted duty; he was categorized as “not in good standing” at retirement, which affected his eligibility to carry a concealed weapon.The Seventh Circuit affirmed summary judgment for the defendants. Dunn lacked evidence that they publicly disclosed stigmatizing information about him. Public disclosure requires actual disclosure, but Dunn pointed to only the possibility of disclosure by FOIA requests or database searches. View "Dunn v. Schmitz" on Justia Law

Officer Layne pulled VanPelt over for driving a car with an illegal window tint and called for backup. When Officer Bennett responded, Layne informed him that “the plate doesn’t come back to the car” and the “car smells like weed.” While patting VanPelt down, Layne found several baggies of marijuana and one baggie of crack cocaine. With VanPelt in handcuffs, Layne led him toward the police car. VanPelt took off running. Four seconds later, Layne tackled VanPelt to the ground, then stood and attempted to pull VanPelt to his feet, briefly grabbing VanPelt’s hair. VanPelt replied that he could not stand because his hip was broken. Layne released his grip. VanPelt fell back to the ground.VanPelt sued Layne for using excessive force and Detroit for failing to adequately train and supervise Layne, 42 U.S.C. 1983. The Sixth Circuit affirmed summary judgment in favor of the defendants, citing qualified immunity. Layne’s tackle and subsequent attempt to lift VanPelt did not violate the Fourth Amendment. Layne’s use of force throughout the encounter was objectively reasonable under the circumstances, even assuming Layne could have stopped VanPelt using a less severe technique. When Layne attempted to lift VanPelt, a reasonable officer would not have known that VanPelt was injured. The record and video did not establish any indication of excessive force nor evidence that Layne had “evil intentions.” View "VanPelt v. City of Detroit" on Justia Law

In 1995, Range pleaded guilty to making false statements about his income to obtain $2,458 of food stamp assistance. His conviction was classified as a misdemeanor punishable by up to five years’ imprisonment. Range was sentenced to three years’ probation. Three years later, Range attempted to purchase a firearm but was rejected by the instant background check system. Range’s wife subsequently bought him a deer-hunting rifle. Years later Range learned that he was barred from purchasing and possessing firearms because of his welfare fraud conviction. He sold his rifle to a firearms dealer and sought a declaratory judgment that 18 U.S.C. 922(g) violated the Second Amendment as applied to him. The section prohibits firearm ownership by any person who has been convicted of a crime punishable by imprisonment for a term exceeding one year—the federal definition of a felony.In 2022, the Third Circuit affirmed the rejection of the suit, reasoning that “the people” constitutionally entitled to bear arms are “law-abiding, responsible citizens,” and that even if Range fell within “the people,” the government demonstrated that its prohibition is consistent with historical tradition.On rehearing, en banc, the Third Circuit reversed. Despite his false statement conviction, Range remains among “the people” protected by the Second Amendment. The government did not carry its burden of showing that the Nation’s history and tradition of firearm regulation support disarming Range. View "Range v. Attorney General United States" on Justia Law

The Supreme Court held that felony resisting arrest constitutes a single unified offense, thus affirming the judgment of the trial court convicting Defendant of felony resisting arrest and other offenses and sentencing him accordingly.On appeal, Defendant argued that the trial court's instruction regarding the elements of resisting arrest under Ariz. Rev. Stat. 13-2508(A)(2) improperly conflated subsections (A)(1) and (A)(2). The court of appeals rejected the argument and affirmed. The Supreme Court affirmed, holding (1) section 13-2508 is ambiguous because it may be reasonably read as setting forth a single unified offense or distinct crimes, and this Court concludes that subsections (A)(1) and (A)(2) are alternative means of committing one offense; (2) this Court's interpretation of section 13-2508 comports with the Sixth Amendment; and (3) because the two subsections set forth a single unified offense the jury instruction regarding this crime did not constitute error. View "State v. Luviano" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Matthew Haney's complaint, brought as the Trustee of the Gooseberry Island Trust, against the Town of Mashpee and its Zoning Board of Appeals, holding that Haney's arguments on appeal were either waived or meritless.Haney brought this action seeking a declaratory judgment that Defendants' actions constituted uncompensated taking of property in violation of the Fifth Amendment of the United States Constitution due to an unconstitutional taking and the Massachusetts Constitution due to inverse condemnation. The district court dismissed the complaint on the grounds that the claims were not ripe for review. The First Circuit affirmed, holding (1) Haney waived his argument relative to whether the government had reached a final decision on the Trust's request for variances; and (2) Haney's remaining arguments were meritless. View "Haney v. Town of Mashpee" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the circuit court's denial of Defendant's petition for postconviction relief, holding that any error during the underlying proceedings that may have violated Defendant's right to confrontation was harmless.Defendant was convicted, after a jury trial, of delivering more than fifty grams of methamphetamine. In his postconviction petition, Defendant argued that the admission of certain testimony was hearsay, and therefore, his right to confrontation under the Sixth Amendment was violated. The circuit court denied relief. The court of appeals affirmed, concluding that if any error occurred it was harmless. The Supreme Court affirmed, holding that, assuming without deciding that Defendant's confrontation right was violated, the error was harmless. View "State v. Barnes" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no error in the underlying proceedings or in the verdict.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress the evidence recovered pursuant to a search warrant following a police trooper's examination of Defendant's vehicle, which was visibly parked in the driveway leading up to his house. The Supreme Judicial Court affirmed, holding (1) because Defendant's vehicle was not parked within the curtilage of his home the trooper's observations of the vehicle did not constitute a search for constitutional purposes; and (2) there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial. View "Commonwealth v. Wittey" on Justia Law

Plaintiff has been incarcerated on death row in Arkansas since 1997. After he was denied relief in state court under Arkansas’s postconviction DNA testing statute, Plaintiff filed this federal lawsuit against several Arkansas officials under 42 U.S.C. Section 1983. Defendants moved to dismiss the complaint on both standing and immunity grounds. The district court denied the motion, and Defendants appealed.   The Eighth Circuit affirmed. The court explained that while Plaintiff does not expressly allege that the Attorney General currently possesses any of the DNA evidence he wants to test, Act 1780 provides the Attorney General an opportunity to play a critical role in the statute’s implementation. And here, the Attorney General responded to Plaintiff’s Act 1780 petition by opposing it in state court. The Attorney General “thereby caused,” in part, Plaintiff’s ongoing injury of being denied access to DNA testing that might prove his innocence. As such, Plaintiff has sufficiently alleged an injury in fact that was caused by Defendants and that would be redressed by the relief he seeks in his Section 1983 action. He has standing to bring his procedural due process challenge to Act 1780. Further, the court found that Defendants here are not immune from suit under the Eleventh Amendment because Plaintiff seeks prospective declaratory and injunctive relief and has alleged a sufficient connection between the defendants and Act 1780’s enforcement. View "Stacey Johnson v. Tim Griffin" on Justia Law