Justia Civil Rights Opinion Summaries

In a custody dispute between Hadzi-Tanovic and her former husband, Pavlovich, an Illinois state court ordered that Hadzi-Tanovic’s parenting time with her children be supervised. She filed suit in federal court under 42 U.S.C. 1983 and 1985 against her ex-husband, the children’s guardian ad litem, and the state court judge, alleging they conspired to violate her and her children’s rights to family association and her right to a fair and unbiased trier of fact. The district court dismissed her complaint on abstention grounds.The Seventh Circuit affirmed. It is well established that federal courts do not have jurisdiction to review such state court decisions. The Rooker-Feldman doctrine imposes a “jurisdictional bar” that prohibits federal courts other than the U.S. Supreme Court from reviewing final state court judgments The state court order at issue is final, so the Rooker-Feldman doctrine’s finality requirement is met. Allegations of state court corruption are not sufficient to avoid the application of the Rooker-Feldman doctrine. Hadzi-Tanovic has not argued that state law or procedures prevented her from raising her federal constitutional issues in state court. Parties may raise procedural and substantive due process challenges to custody orders in Illinois state court. View "Hadzi-Tanovic v. Johnson" on Justia Law

Smucker’s is a federal contractor that supplies food items to the federal government. In 2021, by Executive Order, President Biden directed all federal contractors to “ensure that all [their] employees [were] fully vaccinated for COVID-19,” unless such employees were “legally entitled” to health or religious accommodations. The order made contractors “responsible for considering, and dispositioning, such requests for accommodations.” In September 2021, Smucker’s notified its U.S. employees that it would “ask and expect” them to “be fully vaccinated.” A month later, in the face of “deadlines in the federal order,” Smucker’s announced a formal vaccine mandate with exemptions based on “sincerely held religious beliefs.”The plaintiffs unsuccessfully sought religious exemptions, then sued Smucker's under the First Amendment's free-exercise guarantee. The Sixth Circuit affirmed the dismissal of the suit. When Smucker’s denied the exemption requests, it was not a state actor. Smucker’s does not perform a traditional, exclusive public function; it has not acted jointly with the government or entwined itself with it; and the government did not compel it to deny anyone an exemption. That Smucker’s acted in compliance with federal law and that Smucker’s served as a federal contractor, do not by themselves make the company a government actor. View "Ciraci v. J.M. Smucker Co." on Justia Law

Plaintiff called 911 seeking emergency mental health assistance for the mother of his children, with whom he lived and had five children. This call set in motion a chain of events that ultimately led to the death of Plaintiff’s ten-month-old twin sons at their mother’s own hand.   Plaintiff brought a Section 1983 involving the application of the “state-created danger” doctrine in the context of a welfare check; the Ninth Circuit reversed in part and vacated in part the district court’s dismissal of Plaintiffs’ action for failure to state a claim, and remanded. The panel first made clear that the only two exceptions to the general rule against failure-to-act liability for Section 1983 claims presently recognized by this court were the special-relationship exception and the state-created danger exception. The panel, therefore, rejected Plaintiffs’ assertion that the failure to comply with a legally required duty can give rise to a substantive due process claim. The panel further held that the district court correctly held that the special-relationship exception did not apply here.   The panel next held that Plaintiffs’ state-created danger claim against deputies failed because Plaintiffs failed to allege facts from which one could plausibly conclude that Defendants created or enhanced any danger to the twins. The panel held that Plaintiffs adequately stated their Section 1983 claims against the City of Tulare Police Sergeant under the state-created danger exception. Finally, because the panel reversed the dismissal of some of Plaintiffs’ Section 1983 claims against the social worker and Sergeant, the panel reversed the district court’s dismissal of Plaintiffs’ Monell claims against the County and City of Tulare. View "JOSE MURGUIA V. HEATHER LANGDON, ET AL" on Justia Law

In May 2020, the state transferred 194 inmates from CIM to San Quentin. The transferees were at risk of developing serious symptoms of COVID-19 (persons over the age of 65 and/or with underlying medical conditions); although they had tested negative two weeks prior, several had COVID-19 at the time of the transfer. Some exhibited symptoms before exiting the transfer bus. San Quentin then had no COVID-19 cases among its prisoner population. A month later, at least 1,400 inmates, including Malear, were diagnosed with COVID-19. Several inmates have died from it. Malear filed a putative class action, alleging failure to take reasonable action to summon medical care for prisoners who were in immediate need. The trial court dismissed, holding that Malear had not complied with the Government Claims Act, having filed suit before the rejection of his government claim.The court of appeal reversed, Although Malear filed suit before the denial of his government claim, he filed an amended complaint as of right after the denial and before the defendants were served with the original complaint or appeared in the action. The amended complaint alleged denial of his claim. Malear has established substantial compliance with the statutory requirement. Assuming the truth of the material allegations in the amended complaint, Malear has stated facts sufficient to constitute a cause of action; the complaint does not disclose the existence of a statutory immunity defense as a matter of law. View "Malear v. State of California" on Justia Law

Williams sought compassionate release under 18 U.S.C. 3582(c)(1), citing as “extraordinary and compelling” circumstances the fact that a district court treated him as having a prior conviction for unlawful drug delivery, which increased his minimum sentence, 21 U.S.C. 841(b)(1)(B), while his Illinois conviction for delivery of cocaine did not satisfy the criteria of a “serious drug felony.”The Seventh Circuit rejected that argument, noting its own precedent. Section 3582(c)(1) addresses some new fact about an inmate’s health or family status, or an equivalent post-conviction development, not a purely legal contention for which statutes specify other avenues of relief with distinct requirements, such as the time limits in 28 U.S.C. 2255(f) or the need for a declaration by the Sentencing Commission that a revision to a Guideline applies retroactively. There is nothing “extraordinary” about a legal error and the law provides methods other than compassionate release for dealing with those claims.Williams also argued that he has a spotless conduct record in prison, has completed educational programs that will allow him to participate in society, and has a greater risk of contracting COVID-19 and other diseases in prison. The court rejected those claims for failure to exhaust administrative remedies by presenting them to the Bureau of Prisons. View "United States v. Williams" on Justia Law

The Supreme Court affirmed the judgment of the trial court deciding to grant Defendant's request to represent himself and denying his motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that his waiver of his right to the assistance of counsel was not valid and that the trial justice erred when she denied his motion for a new trial. The Supreme Judicial Court affirmed, holding (1) there was no error in the trial justice's decision allowing Defendant to discharge his attorney when and as he did; and (2) the record established that Defendant made a voluntary, knowing, and intelligent waiver of his right to the assistance of counsel; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Delossantos" on Justia Law

Acting as the decedent’s estate’s administrator and on behalf of his two sons, Plaintiff filed suit against Defendant-Officer. Plaintiff principally sought damages under 42 U.S.C. Section 1983, alleging that Defendant had used constitutionally excessive force—and had thereby “unreasonably . . . seized” Plaintiff’s son in violation of the Fourth Amendment—when she fired the 58th and fatal bullet. She also appended two Georgia law claims: one for assault and battery and another for wrongful death. Defendant moved for summary judgment. She argued that qualified immunity shielded her from suit on the Section 1983 claim and that official immunity protected her from the state-law claims. The district court granted Defendant’s motion.   The Eleventh Circuit affirmed. The court held that in firing the shot that tragically killed Plaintiff’s son, Defendant did not violate the Fourth Amendment. Accordingly, she is entitled to qualified immunity on Plaintiff’s Section 1983 claim. The court reasoned that Defendant was facing down a man who had been threatening to kill her for several minutes straight. He had held a gun to her head, separately pointed his gun at her and her partners, spurned repeated orders to drop his weapons and surrender, barricaded himself in his car, and, finally, opened fire. This man knew how to conceal guns; he was suicidal, dogged, and erratic, and he had shown no signs of backing down. The court wrote it has little trouble concluding that, in those circumstances, Defendant could reasonably have believed that he posed a lethal threat. Her decision to neutralize that threat was “reasonable” and therefore constitutional. View "Iwoinakee Gebray Harris-Billups v. Milele Anderson" on Justia Law

The First Circuit affirmed Defendant's conviction and sentence of a 108-month term of immurement for attempted possession with intent to distribute 400 grams or more of fentanyl, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the First Circuit held (1) Defendant waived his claim that the district court erred by denying his motion to suppress on the grounds that his arrest and the subsequent search of his person were unreasonable; (2) the district court did not plainly error in allowing the testimony of a detective; (3) the evidence was sufficient to support the conviction; and (4) Defendant's sentence was substantively reasonable. View "United States v. Concepcion-Guliam" on Justia Law

The First Circuit affirmed the judgment of the district court concluding that the government had shown by a preponderance of the evidence that Appellant had violated the conditions of his supervised release and sentencing him to a two-year term of imprisonment, holding that there was no error.On appeal, Appellant challenged the district court's determination that the government proved, by a preponderance of the evidence, that he possessed a firearm in violation of the conditions of his supervised release. The First Circuit affirmed, holding (1) a releasee does not have a Sixth Amendment right to confront adverse witnesses during revocation proceedings, and Appellant's remaining constitutional challenge was waived; (2) the district court erred in failing to make the explicit balancing determination contemplated by Fed. R. Civ. P. 32.1(b)(2)(C), but the error was harmless; and (3) the district court's factual findings were not clearly erroneous. View "United States v. Teixeira" on Justia Law

Four police officers unlawfully arrested Plaintiff. Plaintiff sued under 42 U.S.C. Section 1983. The officers appeal the district court’s denial of their summary judgment motion as to (1) excessive force (Officer W.), (2) false arrest (all officers), and (3) fabrication of evidence (Officer L.).   The Fifth Circuit dismissed the appeal and held that it lacked jurisdiction. The court explained that Officer W. argued that Plaintiff took a defensive and threatening posture, resisted being pulled from the vehicle, struggled after being removed, and willfully and aggressively refused to follow commands while resisting the officer’s detainment. Contrary to Officer W.’s argument, those facts are of a genuine dispute. Officer W. failed to take the facts in a light most favorable to Plaintiff, instead relying on facts different from those assumed by the district court. Accordingly, the court wrote that it lacked jurisdiction to consider Officer W.’s appeal of the genuineness of the district court’s factual determinations.   Further, the court addressed the basis of our jurisdiction over Officer L.’s appeal, which does not invoke qualified immunity. Federal courts of appeal have jurisdiction over “appeals from all final decisions of the district courts.” Denial of summary judgment is not a final decision. Thus, the court explained that it lacked jurisdiction over Officer L.’s appeal of this claim. View "Ducksworth v. Landrum" on Justia Law