Justia Civil Rights Opinion Summaries

Kitterman is a frequent litigator in Illinois federal and state courts, in response to Illinois authorities' insistence that he is required to register as a sex offender. Kitterman believes that this obligation has expired. He filed suit under 42 U.S.C. 1983, against defendants from the Belleville Police Department, the St. Clair County Sheriff’s Department, and the Illinois State Police, alleging that the authorities’ continued enforcement of registration duties violated his constitutional rights.The district court dismissed Kitterman’s complaint for failure to state a claim. The Seventh Circuit affirmed. Nothing in federal law calls into question Kitterman’s obligation to register as a sex offender under Illinois law. Even accepting as true that Kitterman’s 1996 conviction was subject to a former Illinois registration law, Kitterman’s current registration duties were triggered in 2011 when he committed additional crimes. The court expressed doubt that a state prosecutor has the power to make the promises that Kitterman described concerning his registration obligations. Kitterman has been under a lawful duty to register ever since his 1996 guilty plea. Kitterman’s federal lawsuit failed because federal constitutional violations cannot be established by showing only that the state officials misapplied state law. View "Kitterman v. City of Belleville" on Justia Law

Two brothers died in a car accident on the way to a school basketball tournament. The brothers were driving to a basketball tournament for their school, Park Christian. The team drove in a three-car caravan: Park Christian's assistant coach and head coach each drove a car of players, with the brothers’ car at the end. During the drive, the head coach cut off a semi-truck, and the semi-truck encroached into the next lane. To avoid a collision, the brothers veered into the median, rolled, and crashed. A Sergeant prepared a Crash Reconstruction Report for the Minnesota State Patrol and found that the brothers’ interaction with the semi-truck caused the accident   Their parents brought claims under 42 U.S.C. Sections 1983 and 1985(2) against Park Christian School, Park Christian administrators, the State of Minnesota, the Minnesota State Patrol, and Minnesota State Patrol officers. The district court dismissed their claims, and Plaintiffs’ appealed. Plaintiffs’ Rule 60.02(b) motion before the state courts alleged that there was a personal connection between the Sergeant and Park Christian which impacted the fairness and impartiality of the Sergeant's investigation and trial testimony   The Eighth Circuit affirmed. The court held that Rooker-Feldman does not apply and that collateral estoppel bars the Section 1983 claim. The court wrote that it is doubtful that the Section 1985(2) claim survives collateral estoppel. But for the purposes of this appeal, the court found that the Section 1985(2) claim fails on the merits. View "Raymond Kvalvog v. Park Christian School, Inc." on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's sixth successive motion for post-conviction relief under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in summarily denying the motion.Appellant was convicted of first-degree felony murder and armed robbery and was sentenced to death. Decades later, Appellant filed the sixth successive post-conviction motion at issue on appeal, arguing that two pieces of allegedly newly discovered evidence required extending the rationale in Roper v. Simmons, 543 U.S. 551 (2005), for barring the execution of defendants under the age of eighteen at the time of the offense to bar the execution of defendants under the age of twenty-one. The circuit court summarily denied relief. The Supreme Court affirmed, holding that the circuit court did not err in finding that Appellant's claim was untimely and that his request to extend Roper was meritless. View "Melton v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Trumbell Correctional Institution, where Appellant was serving a forty-year prison sentence, holding that there was no error.Appellant was serving his prison sentence for nine convictions for felonious assault, in violation of Ohio Rev. Code 2903.11(B)(3). Appellant filed a petition for a writ of habeas corpus arguing, inter alia, that section 2903.11(B)(3) violates the Equal Protection Clauses of the Ohio and United States Constitution. The court of appeals dismissed the petition for failure to state a valid claim for habeas relief. The Supreme Court affirmed, holding that habeas corpus did not lie for Appellant's nonjurisdictional claims. View "Christian v. Davis" on Justia Law

Courtney was sentenced to three years in state prison followed by one year of supervised release for violating an earlier term of parole by failing to register as a sex offender. Courtney’s supervised release was revoked before he left prison. The stated reason was not that he had acted wrongly but that he had no arrangements for a place to live that state officials deemed suitable. Courtney spent his year of supervised release in prison.Courtney brought suit under 42 U.S.C. 1983, alleging that the defendants failed to investigate his proposed living arrangements and ignored his grievances and that his release was revoked without evidence that he violated any terms of release and without adequate procedural protections. The district court dismissed Courtney’s claims as barred by the Supreme Court’s 1994 “Heck” decision, which forecloses civil litigation that would call into question the validity of a state criminal conviction or sentence that has not been set aside or that would call into question the validity of parole revocation, at least when the revocation is based on the parolee’s wrongdoing.The Seventh Circuit affirmed in part but remanded the claims based on the defendants’ failure to do their jobs. Courtney’s claims that the defendants, after his parole revocation, ignored his grievances and communications regarding possible host sites, if substantiated, would not necessarily imply that the Prison Review Board’s decision to revoke his parole was invalid. Courtney’s claims concerning the defendants’ inaction before that date are similar to seeking a writ of mandamus, not like seeking habeas corpus relief, and would not “necessarily demonstrate the invalidity of confinement or its duration.” View "Courtney v. Butler" on Justia Law

Plaintiff alleged (1) Officer N. used excessive force when he tased Plaintiff at the scene of an automobile wreck, (2) Officer H. failed to intervene to prevent Officer N’s excessive force, and (3) the City of Madison, Alabama admitted the officers’ actions were the result of its municipal policy. Relying on body camera footage, Defendants Officer N., Officer H., and the City moved to dismiss. The district court granted their motions to dismiss. On appeal, Plaintiff argued the district court erred by (1) considering the officers’ body camera footage when ruling on Defendants’ motions to dismiss without converting them into summary judgment motions, (2) granting qualified immunity to Officer N., (3) dismissing Plaintiff’s failure-to-intervene claim against Officer H., and (4) dismissing his municipal liability claim against the City.   The Eleventh Circuit affirmed. The court concluded that the district court properly considered the body camera footage, correctly ruled that Officer N. did not violate a constitutional right and thus Officer H. had no duty to intervene and accurately determined that Plaintiff’s claim against the City failed as a matter of law. The court explained Officer N.’s use of the taser was justified because of (1) Plaintiff’s repeated failure to comply with Officer N.’s commands, (2) Plaintiff’s unsafe driving that had just caused an automobile accident, (3) Plaintiff’s repeated efforts to get back in the vehicle, (4) Plaintiff’s physical resistance to Officer N.’s attempts to remove him from the vehicle, and (5) the tense, uncertain, and rapidly evolving series of events. Thus, the court concluded that Officer N.’s single use of a taser in dart mode was objectively reasonable. View "Curtis Baker v. City of Madison, Alabama, et al." on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of two counts of murder in the first degree on the theory of premeditation as to Mark Greenlaw and Jennifer O'Connor and on the theory of extreme atrocity or cruelty as to O'Connor, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in denying Defendant's motion for a mistrial regarding the victim's fear of rape; (2) the prosecutor's statement during closing argument impermissibly appeal to the jury's sympathy, but the statement did not create a substantial likelihood of a miscarriage of justice; (3) the trial judge erred in failing to instruct the jury that it could consider voluntary ingestion of drugs in determining extreme atrocity or cruelty, but the error did not create a substantial likelihood of a miscarriage of justice; (4) the judge did not err in excusing juror number fifteen; (5) the indictment charging attempted burning of a dwelling was not defective; and (6) there was no error warranting relief under Mass. Gen. Laws ch. 278, § 33E. View "Commonwealth v. Doughty" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of kidnapping in the first degree and one count of committing violence against an employee of the Department of Corrections, holding that there was no plain error in the proceedings below.On appeal, Defendant argued that the circuit court erred in failing to conduct a sufficient Faretta hearing to ensure his waiver of counsel was knowing, intelligent, and voluntary and in ordering his sentence to consecutively to his prior sentence, in violation of his plea agreement with the State. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that the circuit court plainly erred in sustaining Defendant's request to represent himself; and (2) the circuit court did not err in ordering Defendant's sentences to run consecutively. View "State v. Teter" on Justia Law

After an overnight stay at the Sheraton St. Paul Woodbury Hotel, Plaintiff sued the Schulte Hospitality Group, Inc. for discrimination and unfair reprisal. Plaintiff claimed he was locked out of the main entrance, greeted inhospitably, forced to provide proof of his Marriott-sponsored Bonvoy rewards program membership at check-in, assigned to a room with dirty bedding, required to bring it to the front desk to exchange for clean bedding, forced to change the bedding himself, and denied a request to switch rooms. The district court granted summary judgment to the Hotel because it provided unrebutted, non-pretextual justifications for its treatment of Plaintiff, and he did not show a causal link between his complaint of discrimination and the Hotel’s adverse actions. Plaintiff appealed.   The Eighth Circuit affirmed. The court explained that Plaintiff failed to show that the Hotel’s reasons are pretextual. He has not provided sufficient probative evidence to support a finding that his treatment in the Hotel was so at variance with the treatment expected of premium hotels during the early months of the COVID-19 pandemic. The district court properly granted summary judgment to the Hotel on the MHRA discrimination claim. Further, the court wrote that because Plaintiff cannot show that the Hotel called the police to escort him out of the Hotel because of his complaints, he failed to satisfy the third element of a prima facie case of MHRA unfair reprisal: “that the adverse action was causally linked to the protected conduct.” View "Larry Johnson v. Schulte Hosp. Group, Inc." on Justia Law

Howell received medical screenings from nurses employed by NaphCare, which contracts with the Jail to provide medical services. Nurses noted his sickle cell disease diagnosis. Howell returned to the medical unit after he started a fight. Video shows Howell repeatedly falling in the hallway. Officers placed Howell in a wheelchair. At the medical sallyport, Howell complained loudly of pain and stated that he could not feel his legs. Howell slid out of the wheelchair and was eventually left on the floor. Nurse Jordan reviewed Howell’s medical chart. Medical staff had previously sent Howell to a hospital for sickle cell pain. Jordan concluded Howell was in pain but was experiencing a psychiatric issue. Around 5:40 p.m., officers placed Howell in a restraint chair, transported Howell to the mental health unit, and placed him in a cell with a small window on its door. At 6:06 p.m., Nurse Arthur checked on Howell, who was still yelling. but decided that he did not need further medical treatment. No NaphCare employee checked on Howell again. Officers checked Howell approximately every 20 minutes by looking through the window, seeing only a side profile. Officers falsified log entries and failed to comply with regulations concerning removal, rotating Howell’s limbs, or providing water or the restroom. At 9:45 p.m., Officers went to remove Howell and found him dead. The coroner determined that Howell died from sickle cell crisis.In a suit under 42 U.S.C. 1983, the district court granted the defendants summary judgment. The Seventh Circuit reversed as to Nurse Jordan and Deputy Erwin on deliberate indifference claims; a reasonable jury could find that they recklessly failed to act to mitigate an unjustifiably high risk of harm to Howell that a reasonable official would have recognized. Erwin was not entitled to qualified immunity. View "Howell v. NaphCare, Inc." on Justia Law