Justia Civil Rights Opinion Summaries

Plaintiff was a long-term employee of Defendant St. Cecilia Catholic School. In her final year of employment, Defendant worked part-time as an art teacher and office administrator. Following her discharge, Defendant filed this action against St. Cecilia for age discrimination in violation of the California Fair Employment and Housing Act (FEHA) The trial court granted St. Cecilia’s motion for summary judgment on the ground that Plaintiff’s suit was barred by the ministerial exception, a constitutional doctrine that precludes certain employment claims brought against a religious institution by its ministers.   The Second Appellate District reversed the judgment in favor of St. Cecilia and remanded for further proceedings. The court concluded that there are triable issues of material fact as to whether the ministerial exception applies in this case. Further, the court wrote that St. Cecilia did not waive the ministerial exception by failing to assert the defense in its answer. The evidence that Plaintiff promoted “Christ-like” behavior in her class does not establish, as a matter of law, that she performed vital religious duties for St. Cecilia or otherwise qualified as a minister. Because there are triable issues of material fact as to whether the ministerial exception applies to Plaintiff’s former job position as an art teacher and an office administrator, St. Cecilia was not entitled to judgment as a matter of law on Plaintiff’s age discrimination suit. View "Atkins v. St. Cecilia Catholic School" on Justia Law

The Supreme Court held that, within the particular facts and overall context of this criminal case, the trial court did not violate either the United States Constitution or the North Carolina General Statutes by declining to conduct further inquiry into Defendant's capacity to proceed following his apparent suicide attempt on the morning of the sixth day of trial.Defendant's suicide attempt occurred before the jury was given its instructions but after the jury had heard closing arguments from both sides. To determine whether Defendant had forfeited his right to be present for the trial's ongoing proceedings the trial court received evidence concerning his medical history and state of mind at the time of his apparent suicide attempt. The court ultimately concluded that Defendant's injuries were entirely caused by his own voluntary actions, and therefore, Defendant had voluntarily absented himself from the trial proceedings. The trial was continued in his absence, and the trial court entered judgments against Defendant. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not erroneously decline to make further inquiry into Defendant's capacity to proceed during the trial proceedings. View "State v. Flow" on Justia Law

The Supreme Court reversed the final order and judgment of the trial court in this case involving challenges to N.C. Gen. Stat. 13-1, the statute setting forth the criteria that felons must satisfy to be eligible for re-enfranchisement, holding that the trial court erred in entering an order allowing all felons not in jail or prison to register and vote.Nearly fifty years after the legislature rewrote section 13-1 to make re-enfranchisement automatic for all eligible felons Plaintiffs brought this action challenging the requirement that felons complete their probation, parole, or post-release supervision before they regain their voting rights. Plaintiffs alleged that this requirement was intended to discriminate African Americans. The trial court ruled for Plaintiffs. The Supreme Court reversed, holding (1) there was insufficient evidence to prove that legislators intended their reforms to section 13-1 to disadvantage African Americans; and (2) Plaintiffs were not entitled to relief on their other constitutional claims. View "Community Success Initiative v. Moore" on Justia Law

The Supreme Court reversed the judgment of the court of appeals holding that S.B. 824 violates N.C. Const. art. I, 19 and permanently enjoining that law, holding that S.B. 824 does not violate the protections set forth in Article I, Section 19.Pursuant to S.B. 824, registered voters are required to present one of several acceptable forms of identification prior to casting a ballot and require the State to provide free voters identification cards to any registered voter. At issue was whether North Carolina's photo identification statute is constitutional. Plaintiffs moved for a preliminary injunction to enjoin implementation and enforcement of S.B. 824. The trial court denied the injunction. The court of appeals reversed, holding that S.B. 824 violates Article I, Section 19 because it was enacted with discriminatory intent. The Supreme Court reversed, holding that Plaintiffs failed to prove beyond a reasonable doubt that S.B. 824 was enacted with discriminatory intent or actually produces a "meaningful disparate impact along racial lines." View "Holmes v. Moore" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, selling sexual relations, and two counts of felony theft, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant argued that the district court erred in determining that her incriminating statements made to law enforcement confessing to the murder were made voluntarily. Among other things, Defendant contended that sleep deprivation and drug use tainted her interview and that her confinement in the interview room was coercive. The Supreme Court affirmed, holding (1) the district court correctly held that Defendant's statements were freely, voluntarily, and knowingly given and admissible at trial; and (2) ample evidence supported the jury's finding of premeditation. View "State v. Spencer" on Justia Law

In 1998, Evans was charged with murder. While awaiting trial, Evans asked his cellmate to kill two witnesses. The cellmate secretly recorded those conversations for the authorities. State charges followed for soliciting murder. In 1999 two separate juries convicted Evans of both murder and solicitation. After Illinois courts affirmed both convictions on direct appeal, Evans filed a petition for postconviction relief in state court in 2003. His petition is still pending. In 2019, frustrated with the delay, Evans invoked 28 U.S.C. 2254 and turned to federal court for relief. He claimed that Illinois’s postconviction relief process had proven “ineffective,” allowing him to seek federal habeas relief without waiting further for relief in the Illinois courts.The Seventh Circuit agreed with Evans and vacated the denial of relief. “The delay Evans has experienced of twenty years and counting is beyond the pale and indefensible.” The exhaustion requirement is neither ironclad nor unyielding. A state-law remedy can become ineffective or unavailable by virtue of delay if the delay is both inordinate and attributable to the state. In this case, the “extraordinary delay has stemmed in no small part from the state’s own conduct, both in its capacity as a respondent to the litigation and as the state trial court itself.” View "Evans v. Wills" on Justia Law

White. convicted of four counts of aggravated murder, two counts of attempted murder, two counts of felonious assault, one count of aggravated burglary, three counts of aggravated robbery, and one count of having a weapon while under disability, was sentenced to life in prison without parole. On appeal, White argued that he had received ineffective assistance of counsel because his attorney, Armengau, was under indictment in Franklin County, Ohio, for serious criminal offenses and “would have been conflicted over whether to devote time to preparing his own defense or that of his client”; “would have been reluctant to vigorously represent White" for fear of angering the prosecutor; and might have failed to engage in plea-bargaining in White’s case out of a desire to gain a victory over the prosecutor. The Ohio Court of Appeals declined to consider White’s claim because the record lacked necessary facts.In White's federal habeas proceedings, the district court found that Armengau had told White about Armengau’s indictment but White had decided to retain Armengau anyway. The Sixth Circuit affirmed the denial of relief. Because White’s claim depends on facts outside the state court record, the Supreme Court’s 2022 "Shinn" decision likely precludes relief. Even considering the new facts introduced in federal habeas court, White’s claim fails. White failed to show that the alleged conflict adversely affected counsel’s performance. White and Armengau’s cases were handled by different judges and were prosecuted by different authorities. View "White v. Phillips" on Justia Law

The Indiana Sex Offender Registration Act (SORA) requires sex offenders who study, work, or reside in Indiana to register with the state. Indiana residents who committed sex offenses either before the Indiana General Assembly enacted SORA or before the Assembly amended SORA to cover their specific offense challenged, under the Equal Protection Clause, SORA’s “other-jurisdiction” provision. That provision requires them to register under SORA because they have a duty to register in another jurisdiction. The Seventh Circuit previously rejected arguments that SORA violated the constitutional right to travel and the Ex Post Facto Clause and concluded that the district court incorrectly applied strict scrutiny to the equal protection claim, remanding for a determination of whether the other-jurisdiction provision survives rational basis review. On remand, the district court concluded that requiring the registration of pre-SORA sex offenders who have a registration obligation in another jurisdiction is not rationally related to a legitimate state interest and granted the plaintiffs summary judgment.The Seventh Circuit reversed. Indiana has a legitimate interest in seeking to register as many sex offenders as the state constitution permits; SORA’s other-jurisdiction provision is rationally related to advancing that interest. The Indiana Supreme Court has held that when an offender is already obligated to register elsewhere, requiring registration in Indiana merely extends that existing duty, which is not punitive and does not offend Indiana’s Ex Post Facto Clause. View "Hope v. Commissioner of Indiana Department of Correction" on Justia Law

Plaintiff saw Defendant, an officer, pointing a firearm at her 12- and 14-year-old sons down the street from their family’s home. When Plaintiff approached to ask what happened, Defendant repeatedly ordered her to “get back.” After Plaintiff questioned the order, Defendant briefly pointed his taser at her. Plainitff then complied with his orders. Her sons were eventually cleared of any wrongdoing. Plaintiff filed a 42 U.S.C. Section 1983 action against Defendant, claiming he used excessive force. The district court granted summary judgment to Defendant on the claim after concluding he was entitled to qualified immunity. Defendant appealed.   The Eighth Circuit affirmed. The court explained that Defendant was placed in a position where he had two possibly armed suspects detained in front of him and a third unknown individual approaching from behind, creating a potentially serious safety risk. Adding to the circumstances, when Defendant ordered Plaintiff to “get back,” she moved to the side, but she did not immediately comply by moving backward. Rather, she questioned the order and moved sideways. Ordered to get back a second time, she again questioned the order and remained where she was until after the taser was drawn. Accordingly, the court wrote that under the totality of the circumstances, Defendant momentarily pointing his taser at Plaintiff to gain control of the scene was not unreasonable. View "Casondra Pollreis v. Lamont Marzolf" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement forced open a lacked box during an inventory search of Defendant's vehicle, holding that the district court did not err.During an inventory search of Defendant's vehicle, the police forced open a locked box and discovered suspected illegal drugs. The State charged Defendant with felony possession of methamphetamine and misdemeanor possession of heroin. Defendant moved to suppress the evidence obtained from the box, arguing that opening the box exceeded the scope of a permissible inventory search in violation of the Wyoming Highway Patrol's (WHP) inventory policy, thus violating his Fourth Amendment rights. The district court denied the motion, after which Defendant entered a conditional plea of guilty to felony possession of methamphetamine. The Supreme Court affirmed, holding that Defendant's argument that the inventory search violated WHP policy was unavailing. View "Beckwith v. State" on Justia Law