Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree murder with the use of a deadly weapon, holding that a district court's invocation of general, as opposed to case-specific, concerns related to the COVID-19 pandemic does not justify dispensing with a defendant's right to in-person confrontation.Appellant fatally shot his girlfriend in a car in which two children were present. During the jury trial, the district court permitted two witnesses to testify remotely via video. On appeal, Defendant argued that his constitutional right to confrontation was violated because the witnesses' convenience did not justify permitting remote testimony and that the district court should have made case-specific findings before summarily ordering that the witnesses may appear remotely. The Supreme Court agreed, holding that because the court did not make the required findings of necessity before allowing the two witnesses to testify remotely Defendant's right to confrontation was violated, but the constitutional error was harmless beyond a reasonable doubt. View "Newson v. State" on Justia Law

The Supreme Judicial Court vacated the judgment of the post-conviction review (PCR) court denying Appellant's PCR petitions, holding that the PCR court misconstrued aspects of the relevant law.In his speedy trial petitions, Defendant argued that his rights to a speedy trial had been violated and that his trial counsel provided ineffective assistance by failing to raise his speedy trial claims. The PCR court denied the petition. Thereafter, Defendant sought a certificate of probable cause. The Supreme Judicial Court vacated the judgment below, holding (1) the PCR court utilized a faulty analysis in concluding that there was no merit to Defendant's speedy trial claim; and (2) because the PCR court did not analyze counsel's strategy in failing to assert Defendant's right to a speedy trial the case must be remanded. View "Winchester v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of one count of aggravated trafficking in scheduled drugs and two counts of criminal forfeiture, holding that the trial court did not err in denying either Defendant's motion to suppress or his motion for discovery.On appeal, Defendant argued that the trial court erred when it denied his motion to suppress and his request for additional discovery relating to the State's cooperating defendant. The Supreme Judicial Court affirmed, holding (1) law enforcement agents had probable cause to support their stop of Defendant, and therefore, the trial court did not err when it denied Defendant's motion to suppress; and (2) the trial court did not abuse its discretion in denying Defendant's discovery motion. View "State v. Lepenn" on Justia Law

Plaintiff, a now-retired Special Agent with the United States Secret Service, filed a civil suit against two United States Park Police officers (“officers”) under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). Plaintiff asserted that the officers violated his rights under the Fourth Amendment by unlawfully seizing him during two traffic stops. A jury found the officers liable for Plaintiff’s emotional injuries resulting from the constitutional violations and awarded him a total of $205,000 in compensatory damages and $525,000 in punitive damages. The district court entered final judgment in accordance with the jury verdict and later denied the officers’ post-trial motions seeking judgment as a matter of law or a new trial.   The Fourth Circuit affirmed. The court concluded that Plaintiff presented a cognizable Bivens claim because his claim is not meaningfully different from the claim asserted in Bivens. Both cases involved allegations of unjustified, warrantless seizures in violation of the Fourth Amendment committed by federal “line” officers conducting routine police work. Also, the officers were not entitled to qualified immunity. They violated Plaintiff’s Fourth Amendment rights by significantly prolonging the initial stop without justification and by initiating a second, unjustified stop. This constitutional right to be free from such unlawful seizures was clearly established at the time the seizures occurred. Further, the court held that Plaintiff presented sufficient evidence of emotional injury to support the compensatory damage award, and the punitive damages award was not excessive. View "Nathaniel Hicks v. Gerald Ferreyra" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of stalking his ex-wife, holding that Defendant was not denied his right to a speedy trial and that the trial court did not commit prejudicial error in instructing the jury.After a jury trial, Defendant was found guilty of one count of felony stalking and sentenced to four to six years in prison. The Supreme Court affirmed, holding (1) Defendant was not denied his right to a speedy trial under either Wyo. R. Crim. P. 48 or the Sixth Amendment to the United States Constitution; and (2) the district court abused its discretion by giving instruction number fourteen because it described stalking as a general intent crime when it, in fact, is a specific intent crime, but Appellant did not meet his burden to demonstrate prejudice. View "Person v. State" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court denying Defendant's motion to suppress, holding that the articulable facts combined to establish reasonable suspicion that Defendant had committed armed robbery.At issue was whether information known to other investigating officers may be imputed to the officer who initiated the stop under the collective knowledge doctrine. The superior court judge denied Defendant's motion to suppress evidence obtained as a result of a stop, concluding that the officer who conducted an investigatory stop on Defendant had adequate reasonable suspicion to do so. The appeals court affirmed. The Supreme Judicial Court affirmed, holding that, with or without the imputed knowledge, the officer who stopped Defendant had reasonable suspicion to do so. View "Commonwealth v. Privette" on Justia Law

In May 2017, La’Shadion Shemwell was elected to the McKinney City Council. Shemwell’s term was cut short when the voters recalled him in November 2020. Shemwell claimed that the McKinney recall election procedures violate the Fourteenth and Fifteenth Amendments, 42 U.S.C. Section 1983, and Section 2 of the Voting Rights Act.  Six months after dismissing his first lawsuit and two months before his recall election, Shemwell filed this suit on September 13, 2020. He asserted the same claims, this time with an additional Plaintiff— a Latina District 1 voter. The district court held the case moot, declined to apply the “capable of repetition, yet evading review” exception, and granted the City’s motion to dismiss. The sole issue on appeal is whether the November 2020 recall election mooted Plaintiffs’ claim for prospective declaratory relief.   The Fifth Circuit found that the November 2020 election mooted this case and held that Plaintiffs’ failed to satisfy the “capable of repetition, yet evading review” mootness exception. The court explained that Shemwell—in his official capacity—failed to claim or prove that he was likely to run again for District 1, win, and face the allegedly unlawful recall provisions. And Plaintiffs’—in their capacity as voters—failed to claim or prove that there was more than an “abstract or hypothetical” possibility that they would ever vote in another recall election of a District 1 Council Member. Thus, any judgment issued after the recall election would have been an impermissible advisory opinion. Further, Plaintiffs repeatedly abandoned their claims for injunctive relief—and never pursued expedited relief. View "Shemwell v. McKinney, Texas" on Justia Law

A man walked into Walgreens wearing clothes with white stains, placed a pack of gum on the counter, asked for cigarettes, then pulled out an apparent handgun. The man fled with the money and the cigarettes, leaving the gum. Police found Jacobs’s fingerprint on the gum and got an arrest warrant. Jacobs learned of the warrant and voluntarily went to the police station. Jacobs met with Detective Agee, who read him his Miranda rights. Showing Jacobs pictures from the Walgreens robbery and other robberies, Agee noted that the stains on the robber’s clothes resembled stains on Jacobs’s jacket. Jacobs denied involvement in the robberies. Agee highlighted the strength of the fingerprint evidence and said that he would get a warrant to search Jacobs’s dad’s house, where Jacobs was living, and Jacobs’s car. Agee said that Jacobs would likely face a severe sentence but things might be different if Jacobs changed his story. Jacobs then said: “The weapons—them is gone.” Agee gave Jacobs a phone to make calls and offered food and drink. After a break, Jacobs said he “f—ed up bad” because he was “broke” and needed to pay child support. He made statements about the gun and helped police retrieve the clothes from his girlfriend’s house. The interview lasted less than two hours.The district court granted Jacobs’s suppression motion, concluding that Agee used impermissibly coercive tactics. On interlocutory appeal, the Sixth Circuit reversed. Jacobs’s statements were voluntary. View "United States v. Jacobs" on Justia Law

Plaintiff suffers from a condition that causes her to faint from positional changes, particularly in hot weather. Plaintiff sometimes utilizes a wheelchair. She was doing so in September 2019 when she went to her local Office of Motor Vehicles (OMV) to have her address changed on her driver’s license. Because Plaintiff was in a wheelchair, OMV employees asked that Plaintiff have her doctor fill out the entirety of a short medical form regarding possible conditions related to her ability to drive. Plaintiff later sued the State of Louisiana, the Department of Public Safety and Corrections, the Office of Motor Vehicles, and Secretary James LeBlanc, in his official capacity as Secretary of the Department of Public Safety and Corrections. In her amended complaint, Plaintiff claimed that OMV violated the ADA and the Rehabilitation Act by (1) determining that she required additional screening before renewing her license solely because she was in a wheelchair and (2) failing to offer her reasonable accommodation. The district court dismissed Plaintiff’s claim at the summary judgment stage.   The Fifth Circuit affirmed. The court held that the scope of the ADA is broad, but it is not so broad as to encompass Plaintiff’s claims here, where she was asked to endure a minimal—at most—burden to ensure safety on the public roadways. The court, having found that the State’s request that Plaintiff has her physician fill out the medical form did not violate the ADA via disparate treatment or failure to accommodate, similarly found as a matter of law that the State did not act with “something more than deliberate indifference” toward Plaintiff’s disability. View "Clark v. State of LA, Dept of Pub Sfty" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing the claim brought by the Back Beach Neighbors Committee alleging that the Town of Rockport, Massachusetts committed a class-of-one equal protection violation by failing adequately to enforce local rules against scuba divers at Back Beach, holding that the district court did not err.The Committee brought this complaint claiming that the Town's failure consistently to enforce various rules as to Back Beach led to the singling out of the beach as a place "to welcome divers." The district court granted the Town's motion to dismiss as to six of the complaint's eight counts and then granted summary judgment for the Town on the remaining counts. The First Circuit affirmed, holding that because the Committee did not plausibly allege the existence of similarly-situated comparators, its class-of-one equal protection claim failed. View "Back Beach Neighbors Committee v. Town of Rockport" on Justia Law