Justia Civil Rights Opinion Summaries

The Supreme Court reversed the decision of the court of criminal appeals reversing Defendant's convictions and reinstated the judgments of the trial court, holding that the intermediate court erred when it stated that an involuntary confession claim is "inextricably linked" to a Miranda waiver claim such that the two inquiries can be considered together.Defendant, a juvenile at the time of the offenses, was convicted of aggravated robbery, premeditated first-degree murder, two counts of first-degree felony murder, and theft of property valued at over $10,000. Defendant was sentenced to life in prison for the murder conviction. On appeal, the court of criminal appeals reversed the denial of Defendant's motion to suppress pretrial statement to detectives, concluding that the statement was not voluntary. The Supreme Court reversed, holding (1) Defendant's overall statement was voluntary, and his Miranda waiver was both knowing and voluntary; and (2) the evidence presented by the State was sufficient to support Defendant's conviction for premeditated first-degree murder. View "State v. McKinney" on Justia Law

The Supreme Court reversed the order of the circuit court suppressing statements made by Defendant during the execution of a search warrant, holding that the circuit court erred in concluding that Defendant's statements to a law enforcement officer during the execution of a search warrant were involuntarily made.Defendant was indicted for one count each of rape in the third degree and sexual contact with a person incapable of consenting. Defendant filed a motion to suppress the statements he made to law enforcement, arguing that his statements were obtained in violation of Miranda v. Arizona, 384 U.S. 436 (1996). The circuit court granted the motion, concluding that Defendant's statements were involuntarily made under the Due Process Clause. The Supreme Court reversed, holding that, based on a review of the totality of the circumstances, the circuit court erred in concluding that Defendant's statements to law enforcement were involuntarily made. View "State v. Ghebre" on Justia Law

Howard was charged as a felon in possession of a weapon. Before his trial, the government struck the only three Black jurors on the 39-person venire panel. The judge had admonished the jurors that they could not use the internet for any purpose related to or surrounding the case and asked the jurors to “[r]aise your number if you don’t use the internet.” Jurors 9, 13, and 24 each raised their numbers. Jurors 9 and 24 were two of the three Blacks. The prosecutor struck each of them, explaining: “I do not believe people when they say they don’t use the Internet.” In response to the defendant’s subsequent Batson challenge, the court applied the three steps of the Batson inquiry. At the third step—that the defendant established purposeful discrimination by the government—the court summarized Howard’s counsel’s argument, stating: “Your sole justification and your persuasiveness is that the government attorney, who does happen to be African-American, has struck every single African-American on the panel.”The Seventh Circuit affirmed Howard’s conviction, rejecting arguments that the district court erred by injecting the prosecutor’s race into the Batson inquiry, improperly evaluating the peremptory strike, and failing to make required demeanor findings. The prosecutor’s theory was not so “implausible or fantastic” as to require a conclusion that the justification was “pretext[] for purposeful discrimination.” View "United States v. Howard" on Justia Law

Nashville passed a “sidewalk ordinance.” To obtain a building permit, an owner must grant an easement across their land and agree to build a sidewalk on the easement or pay an “in-lieu” fee that Nashville will use to build sidewalks elsewhere.In a challenge to the ordinance under the Fifth Amendment’s Takings Clause, the landowner plaintiffs asked the court to apply the “unconstitutional-conditions” test that the Supreme Court adopted in 1987 to assess conditions on building permits (Nollan v. California Coastal Commission). Nashville argued that the Court has applied Nollan’s test only to ad hoc administrative conditions that zoning officials impose on specific permit applicants—not generally applicable legislative conditions that city councils impose on all permit applicants. For legislative conditions, Nashville argued in favor of the application of the deferential “balancing” test that the Court adopted to assess zoning restrictions in “Penn Central” (1978). The district court granted Nashville summary judgment.The Sixth Circuit reversed, agreeing with the landowners. Nothing in the relevant constitutional text, history, or precedent supports Nashville’s distinction between administrative and legislative conditions. Nollan’s test should apply to both types, including those imposed by the sidewalk ordinance. View "Knight v. e Metropolitan Government of Nashville and Davidson County" on Justia Law

Plaintiff Jeffrey Helvie appealed a district court’s decision to grant Defendant Chad Jenkins, an Adams County, Colorado, deputy sheriff, qualified immunity on Helvie’s claim that the deputy used excessive force against Helvie during a traffic stop. On August 23, 2018, at approximately 11:45 p.m., Deputy Jenkins observed Plaintiff make several traffic infractions while driving a Nissan pickup truck. The vehicle window was partially down when Deputy Jenkins approached. According to Deputy Jenkins, he could smell the strong odor of burnt marijuana coming out of the window, though Plaintiff disputed having smoked marijuana that day. Plaintiff handed his driver’s license and registration to Deputy Jenkins, but had difficulty providing his proof of insurance (which was on his phone) due to either poor cellular reception or Plaintiff's inability to correctly enter a passcode. According to Deputy Jenkins, he believed that Plaintiff was operating a vehicle while under the influence and wanted to conduct further investigation. When Plaintiff did not get out of the vehicle, Deputy Jenkins grabbed Plaintiff's arm and ordered him out of the vehicle. According to Deputy Jenkins, Plaintiff pulled away. Deputy Jenkins then grabbed Plaintiff's leg and pulled him out of the vehicle, causing Plaintiff to land on his back. As Deputy Jenkins was pulling Plaintiff out of the vehicle, he observed a handgun in the pocket of the driver’s side door. After review of Plaintiff's complaint, the Tenth Circuit determined he failed to show that Deputy Jenkins violated his constitutional rights and, necessarily flowing from that holding, Plaintiff failed to show that his constitutional rights allegedly violated were clearly established. View "Helvie v. Jenkins" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony possession of methamphetamine, holding that the district court did not err in denying Defendant's multiple motions to suppress challenging the validity of the warrant and supporting affidavit police obtained to search his residence.On appeal, Defendant argued that Officer Andy Lucas of the Gillette Police Department knowingly, or with reckless disregard, omitted facts from the search warrant affidavit and that the warrant was not sufficiently particular to remain valid under the Fourth Amendment. The Supreme Court disagreed, holding (1) the district court did not clearly err in finding Officer Lucas had not recklessly omitted information from the affidavit; and (2) the search warrant contained sufficient information to allow Officer Lucas to identify the place to be searched with reasonable effort. View "Herdt v. State" on Justia Law

Plaintiff, is a Mississippi state inmate. Defendant is a physician and at relevant times was the medical director at the state facility where Plaintiff was housed. Because Plaintiff suffers from a complex psychiatric profile, Plaintiff’s cell was inside the facility’s medical unit. As a result of Plaintiff’s incitement, other prisoners, many of whom were also psychiatric patients, began to act similarly. Defendant went to the scene, as did as many as nine other staff members. There, Defendant asked Plaintiff to desist several times. Plaintiff did not. Defendant then ordered that Plaintiff receive two injections: Haldol, an antipsychotic, and Benadryl, an antihistamine intended as a prophylactic against any complication from Haldol. Plaintiff went to sleep following the injections, and nearby inmates quieted down. Afterward, Plaintiff filed a 42 U.S.C. Section 1983 suit alleging that Defendant’s decision to forcibly medicate Plaintiff violated Plaintiff’s civil rights. The district court, relying on Fourteenth Amendment substantive due process jurisprudence and out-of-circuit opinion, agreed.   The Fifth Circuit reversed. The court held that the district court erred when it declined to apply an Eighth Amendment framework to Plaintiff’s dispute over medical treatment. And, even if a Fourteenth Amendment framework were apposite, Plaintiff received all the process he was due. The court explained that it’s not as if Defendant suddenly and arbitrarily injected Plaintiff. Rather, Defendant injected him only after Plaintiff precipitated a disturbance that subjectively appeared imminently dangerous, only after multiple rounds of verbal persuasion failed, and only after a licensed medical professional determined that medication was appropriate. View "Pinkston v. Kuiper" on Justia Law

Plaintiff was an inmate in a Texas state prison. He was treated at a prison clinic and then discharged after the nurses told Plaintiff they believed he was "faking" his symptoms. Plainitff later experienced a brain stem stroke. Plaintiff filed a Section 1983 claim, asserting prison staff denied him access to emergency medical treatment. The district court dismissed Plaintiff's claim.On appeal, Plaintiff claimed that the district court (1) erred in resolving disputed facts during screening; (2) erred in concluding that he failed to state a claim; (3) erred in determining that the warden and medical director were not liable as supervisors; and (4) abused its discretion in failing to rule on pending motions. The Fifth Circuit affirmed, finding that Plaintiff's claim was not a constitutional tort, but instead a medical malpractice claim. View "Thompson v. TDCJ" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of fifth-degree possession of a controlled substance, holding that the search of Defendant's purse was constitutional under the automobile exception to the Fourth Amendment's search warrant requirement.Defendant, a passenger in a vehicle searched by law enforcement without a warrant, removed her purse from the car as she got out, but an officer directed her to leave the purse on the car. The officer's ensuing search of the purse revealed a controlled substance. Defendant filed a motion to suppress, arguing that the automobile exception did not apply because the purse was an extension of her person, not a container within the car. The district court denied the motion. The court of appeals affirmed the denial, concluding that the warrantless search of Defendant's purse was constitutional. The Supreme Court affirmed, holding that (1) the purse was a container that was inside the car at the time probable cause arose; and (2) because the purse could have contained marijuana, the officer was permitted to search it under the automobile exception. View "State v. Barrow" on Justia Law

Former inmate Morgan, a devout Muslim, sued Michigan prison officials for allegedly violating his free exercise rights by failing to provide him with meals consistent with his religion after he was transferred to a prison that lacked the capacity to produce compliant meals. Morgan filed a grievance with the prison five days after he arrived. The district court granted the defendants summary judgment based on Morgan’s failure to exhaust administrative remedies under the Prison Litigation Reform Act of 1995, 42 U.S.C. 1997e, which requires prisoners to follow a prison’s grievance procedures before challenging prison conditions in court. The district court held that Morgan’s grievance only covered the failure to provide meals up until the date of the grievance, so Morgan should have filed further grievances as to the alleged free exercise violation.The Sixth Circuit reversed. Morgan already put the prison officials on notice of unconstitutional conduct; requiring repeat grievances for the same course of conduct would exceed the requirements of the Act. At issue here is Morgan’s free exercise claim, which he raised by prison grievance. The facts Morgan has pled along with this claim, including staff laughing at him, are sufficiently ancillary to require no further exhaustion of his claim. View "Morgan v. Trierweiler" on Justia Law