Justia Civil Rights Opinion Summaries

Harris went to the store, argued with a clerk, left the store, and entered the laundromat next door where his friend, Henderson, worked. Harris asserts that while he was between the buildings, the clerk came out, pointed a gun, and taunted him with racial slurs. Following Harris’s 911 call, four officers arrived. As shown on bodycams, they expressed disbelief in Harris’s report. The store clerk denied having a gun. The store had at least three surveillance cameras but the officers watched footage from only the front door, although Harris had reported that the incident occurred near the back door. Harris wanted to move forward with his report, believing the footage would corroborate his account. The officers indicated that the video revealed Harris had lied and arrested Harris. No officer took Henderson’s statement. Detective Busch reviewed the police report and passed it to the prosecutor for charging.Harris spent 18 days in jail before being released on bond. Weeks later, the state dropped Harris’s false felony report charge; the store clerks failed to appear. Harris sued the City of Saginaw, the officers, and Busch. The Sixth Circuit affirmed the denial of qualified immunity summary judgment to the officers, the grant of qualified immunity to Busch, and the dismissal of Harris’s failure-to-train and failure-to-supervise claims against the city. There is a genuine dispute of material fact regarding whether the officers arrested Harris without probable cause. View "Harris v. City of Saginaw, Michigan" on Justia Law

Plaintiff sued Defendants for violating his First and Fourteenth Amendment rights by recommending and imposing certain special conditions of post-release supervision that he contends is unconstitutional. The district court declined to grant Defendants summary judgment.   At issue in this appeal is whether a corrections professional who recommended that the Parole Board issue certain special conditions of release is absolutely or qualifiedly immune from claims challenging the constitutionality of those conditions and seeking monetary or injunctive relief.  The Second Circuit reversed and remanded. The court concluded that the Commissioner’s is absolutely immune from Plaintiff’s claims for damages because her challenged acts were quasi-judicial. The court did not address the Offender Rehabilitation Coordinator’s claim of absolute immunity but concluded that she is qualifiedly immune from Plaintiff’s damage claims because the challenged conditions were not clearly unlawful at the time she recommended them.   The court reasoned that to the extent Plaintiff is challenging the delegation of broad authority to the parole officer, the court noted that parole officers are statutorily authorized to impose special conditions. Plaintiff has not cited any law narrowing this authority. In sum, Plaintiff has failed to demonstrate that the parole officer’s recommendation of these case-specific conditions violated his clearly established rights. View "Peoples v. Leon, et al." on Justia Law

The Equal Employment Opportunity Commission (EEOC) sued Methodist Hospitals of Dallas (Methodist) for allegedly violating the Americans with Disabilities Act (ADA). The EEOC asserts that Methodist’s categorical policy of hiring the most qualified candidate violates the ADA when a qualified disabled employee requests reassignment to a vacant role, even if he or she is not the most qualified applicant. The EEOC also alleged that Methodist failed to reasonably accommodate a disabled employee, who was not reassigned to a vacant position for which she applied. The district court granted Methodist’s motion for summary judgment on both claims. The EEOC appealed, arguing that the Supreme Court’s ruling in US Airways, Inc. v. Barnett requires Methodist to make exceptions to its most-qualified-applicant policy and that the employee was entitled to a reasonable accommodation under the ADA.   The Fifth Circuit vacated the judgment of the district court as to Methodist’s most-qualified-applicant policy and remand for further proceedings consistent with this opinion. The court affirmed the judgment as to the EEOC’s reasonable accommodations claim involving the employee. The court explained that at summary judgment, an employee’s “unilateral withdrawal from the interactive process is fatal to her claim,” so long as the employer “engaged in a good-faith, interactive process with the employee regarding her request for a reasonable accommodation.” Based on the evidence, no reasonable jury could find that Methodist was unwilling to participate in the interactive process. When the employee did not respond to either the August 7th letter or the follow-up letter after her appeal of her termination, she caused the breakdown of the interactive process. Thus, Methodist did not act unlawfully. View "EEOC v. Methodist Hospitals" on Justia Law

The Supreme Court reversed the opinion of the court of appeals reversing Defendant's convictions for driving after cancellation-inimical to public safety (DAC-IPS) based on the conclusion that Minn. Stat. 171.24, subd. 5 is unenforceable on private property, holding that the statute is enforceable on private property.Defendant, whose license was cancelled as inimical to public safety, was charged with DAC-IPS after a law enforcement officer observed him drive a motor vehicle down a private driveway. Defendant filed a motion to suppress and to dismiss the complaint for lack of probable cause. The district court denied the motions. The district court subsequently found Defendant guilty. The court of appeals reversed, ruling that the DAC-IPS requires a license only when a vehicle is operated on a street or highway. The Supreme Court reversed, holding (1) the DAC-IPS statute is enforceable in private property; and (2) the district court properly denied Defendant's motions to suppress and dismiss, resulting in restatement of Defendant's convictions. View "State v. Velisek" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting the petition for a writ of prohibition filed by the State prohibiting the district court from enforcing a "taint team" order, holding that the district court erred in concluding that the Sixth Amendment right to counsel was implicated in this case.Appellant, a juvenile at the time of his offense, was convicted of first-degree premeditated murder and sentenced to two consecutive sentences of life without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, Appellant was granted resentencing. At issue during the hearing was copies of recorded calls made by Appellant while he was incarcerated. The district court ordered the State to use a taint team to review the recorded calls for attorney-client communications on the ground that Appellant's the constitutional right to counsel was implicated. The court of appeals granted the State's petition for a writ prohibiting the court from enforcing the taint team order. The Supreme Court affirmed, holding that relief was not warranted because (1) the Sixth Amendment was not implicated here; and (2) the State would be injured and without any adequate remedy to correct the unauthorized action of the court. View "State v. Flowers" on Justia Law

Moss purchased cocaine from a DEA informant and was charged with possession with intent to deliver 1,000 or more grams of cocaine and possession of a firearm during the commission of a felony. Moss’s first attorney moved for an entrapment hearing. Steingold then began representing Moss. At the entrapment hearing, 10 days later, Steingold attested to minimal pre-trial preparation. Moss was the only witness he presented. Steingold requested a continuance to contact witnesses he learned about during Moss’s direct and cross-examination. The court permitted Steingold to contact one witness but denied a continuance. The prosecution presented five witnesses and multiple exhibits. The court denied Moss’s motion to dismiss based on entrapment.At trial, Steingold waived his opening argument, presented no witnesses, and stipulated to the admission of the transcript from the entrapment hearing as substantive evidence. For one of the government’s two witnesses, Steingold did not object during his testimony or conduct any cross-examination. Steingold waived his closing argument. On appeal, Moss unsuccessfully argued that Steingold provided constitutionally ineffective assistance by waiving Moss’s right to a jury trial and stipulating to the admission of the evidence from the entrapment hearing.The Sixth Circuit reversed the district court’s order of habeas relief. The state court’s denial of Moss’s ineffective assistance claims under Strickland was not contrary to nor an unreasonable application of clearly established federal law. View "Moss v. Miniard" on Justia Law

Freeman was convicted, along with Miller and Collier, of second-degree murder. The jury had heard the confession of Miller, a non-testifying codefendant, with redactions that replaced the names of Collier and Freeman, with the substitutes “the first guy” and “the second guy.” The court gave a limiting instruction that the statement was to be considered only as to Miller, not as to the other defendants, in order to protect Freeman’s Sixth Amendment right to confront a witness against him. Freeman’s objection was overruled and rejected on appeal in state court.The district court concluded that a “Bruton” violation occurred and that the violation was not harmless, and granted Freeman habeas relief. The Third Circuit reversed. A Bruton violation occurred. When a statement is redacted— whether by substituting the codefendant’s name with a neutral pronoun, a blank space, or a symbol—in such a manner that “[a] juror … need only lift his eyes to [the codefendant], sitting at counsel table” to understand who is being implicated, the introduction of that statement is a Sixth Amendment violation. However, there was ample other evidence against Freeman, and the violative statement was largely duplicative of other evidence; there is no “grave doubt about whether [the error] had substantial and injurious effect or influence in determining the jury’s verdict.” The error was harmless. View "Freeman v. Superintendent Fayette SCI" on Justia Law

Individuals Plaintiffs, Uber, Inc. (Uber) and Postmates, Inc. (Postmates, and collectively Plaintiffs) appealed the district court’s orders denying their motion for a preliminary injunction and dismissing their Second Amended Complaint. Plaintiffs filed this action to enjoin the State of California and the Attorney General of California (Defendants), from enforcing California Assembly Bill 5, 2019 Cal. Stats. Ch. 296 (A.B. 5), as amended by California Assembly Bill 170, 2019 Cal. Stats. Ch. 415 (A.B. 170) and California Assembly Bill 2257, 2020 Cal. Stats. Ch. 38 (A.B. 2257, and collectively A.B. 5, as amended), against them. A.B. 5, as amended, codified the “ABC test” adopted by the Supreme Court of California in Dynamex Operations West, Inc. v. Superior Court of Los Angeles, 4 Cal. 5th 903 (2018).1 A.B. 5, as amended, however, incorporated numerous exemptions into its provisions.   The Ninth Circuit affirmed in part and reversed in part district court orders dismissing Plaintiffs’ Second Amended Complaint and denying Plaintiffs’ motion for a preliminary injunction and remanded. The panel first held that, even under the fairly forgiving rational basis review, Plaintiffs plausibly alleged that A.B. 5, as amended, violated the Equal Protection Clause for those engaged in app-based ride-hailing and delivery services. Thus, Plaintiffs plausibly alleged that the primary impetus for the enactment of A.B. 5 was the disfavor with which the architect of the legislation viewed Uber, Postmates, and similar gig-based business models. The panel held that the district court correctly dismissed Plaintiffs’ due process claims because Plaintiffs failed to plausibly allege that A.B. 5, as amended, completely prohibited them from exercising their “right to engage in a calling.” View "LYDIA OLSON, ET AL V. STATE OF CALIFORNIA, ET AL" on Justia Law

Plaintiff sued the State of California, and Rob Bonta and Xavier Becerra in their capacities as the current and former Attorney General after a federally licensed firearms dealer refused to complete Plaintiff’s purchase of an antique shotgun. Plaintiff alleged the dealer had received a letter from the Department pursuant to section 28220, subdivision (f)(4), advising it that the Department had been unable within the statutory period to ascertain Plaintiff’s eligibility to purchase the firearm. Although the Department’s letter, in accordance with section 28220, subdivision (f)(4), authorized the immediate transfer of the firearm to Plaintiff at the dealer’s discretion, the dealer elected not to do so, telling Plaintiff it was unwilling to “take the risk.” In his operative second amended complaint, Plaintiff alleged a federal civil rights claim and requested declaratory relief.   The Second Appellate District affirmed. The court explained Plaintiff’s causes of action are premised on the contention that section 28220, subdivision (f)(4), violates the Second Amendment or is preempted by federal law. Both arguments are wrong as a matter of law. Because Plaintiff has not demonstrated how his complaint could be amended to state viable claims, the trial court did not err in sustaining the State’s demurrer to the second amended complaint without leave to amend. View "Regina v. State of California" on Justia Law

Appellant, a United States citizen and veteran, alleges Appellees (Foreign Officials) detained and tortured him in the Democratic Republic of the Congo (DRC). Appellant argued that the Foreign Officials did so to extract a false confession that he was an American mercenary. That is enough, in Appellant’s view, to establish that the district court had personal jurisdiction over the Foreign Officials. If not, he asserts alternatively that jurisdictional discovery is warranted.   The DC Circuit affirmed the district court’s grant of the Foreign Officials’ motion to dismiss for lack of personal jurisdiction and its denial of Appellant’s request for jurisdictional discovery. The court explained traditional notions of fair play and substantial justice do not save Appellant’s complaint. The court held Appellant failed to demonstrate that exercising specific jurisdiction over the Foreign Officials, in this case, would meet the requirements of the Fifth Amendment’s Due Process Clause. And he also failed to describe particular ways in which jurisdictional discovery would cure his complaint’s defect. View "Darryl Lewis v. Kalev Mutond" on Justia Law