Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the opinion of the court of appeals affirming the decision of the district court to allow a witness to testify using live, two-way remote view technology during a jury trial in the midst of the COVID-19 pandemic, holding that Defendant's right to confrontation was not violated in the proceedings below.During Defendant's jury trial on a third-degree sale of a controlled substance charge, the district court allowed one of the State's witness to testify via Zoom because she had been exposed to COVID-19 and was forced to quarantine. Defendant appealed. The Supreme Court affirmed, holding (1) the two-part test set forth in Maryland v. Craig, 497 U.S. 836 (1990), is the appropriate test to assess whether a Confrontation Clause violation under the federal or state constitutions; and (2) Defendant's right to confrontation under the federal and state constitutions when the district court permitted the witness to testify using remote view technology under the circumstances of this case. View "State v. Tate" on Justia Law

The Supreme Court reversed Defendant's conviction for two counts of aggravated sexual assault of a minor and two counts of risk of injury to a child, holding that the trial court improperly failed to order that certain material be turned over to the defense and that the error was not harmless beyond a reasonable doubt.On appeal, Defendant argued, among other things, that the trial court violated his Sixth Amendment right to confrontation by not ordering disclosure of the victims' psychiatric records to the defense. The Supreme Court agreed, holding that the trial court (1) committed harmful error by failing to order that exculpatory and relevant impeachment material contained in the victims' psychiatric records be turned over to the defense; (2) improperly precluded cross-examination of the mothers of the victims concerning their U visa applications; and (3) improperly instructed the jury. View "State v. Juan A. G.-P." on Justia Law

The decedent committed suicide in his cell. On behalf of her minor child, Plaintiff sued the warden at Ouachita Correctional Center (“OCC”) and the sheriff of Ouachita Parish in their official capacities; she also purports to have sued them in their individual capacities. All federal claims are brought under 42 U.S.C. Section 1983 for violations of the decedent’s Eighth Amendment rights. Plaintiff additionally sued under related state laws for negligence and vicarious liability. The district court granted summary judgment.   The Fifth Circuit affirmed. The court explained the warden cannot be sued in his official capacity. Official-capacity suits may be brought only against an official acting as a policymaker. Further, although the sheriff can be sued in his official capacity, those claims also fail. The Sheriff, as the final policymaker in the Parish, does satisfy the second requirement of the analysis and can be sued in his official capacity, assuming Plaintiff provides evidence that the conduct prong is met. However, Section 1983 does not allow recovery under a theory of respondeat superior; a plaintiff must show that the local government’s policy or custom violated the plaintiff’s constitutional rights. Moreover, the court explained that even if Plaintiff adequately pleaded her individual-capacity claims, she has not alleged a genuine dispute as to any material fact to hold defendants responsible under a supervisory-liability theory. View "Guillot v. Russell" on Justia Law

Before the 2016 Democratic National Convention, the Secret Service announced that access to certain areas would be restricted. Graber, a paramedic, joined political protests outside the Restricted Area. Protestors breached the gated perimeter. The Philadelphia Police Department apprehended those within the Restricted Area. Graber was one of seven individuals taken into custody; the police did not prepare any arrest paperwork for Graber. Special Agent Boresky was charged with serving as an affiant for a criminal complaint against the arrestees. Another agent e-mailed Boresky a synopsis of the events and photographs. Boresky appeared before a Magistrate and signed an affidavit identifying Graber as having been arrested inside the Restricted Area, based upon his “personal knowledge,” “information developed during the course of this investigation,” and information 'imparted by other officers. Boresky was not present at the arrest, did not view any video evidence, and did not write the affidavit. Graber was detained overnight. Graber’s counsel provided news video clips confirming that Graber never passed through the fence. The charges against Graber were dismissed.Citing “Bivens,” in which the Supreme Court held that a cause of action existed against federal agents who violated the Fourth Amendment, Graber sued Boresky for false arrest, unlawful detention, and false charges. Denying a motion to dismiss, the district court held that a Bivens claim could be brought against Boresky. The court later dismissed Boresky’s qualified immunity summary judgment motion. The Third Circuit dismissed an appeal for lack of jurisdiction; the Bivens ruling is not a final decision and is not appealable under the collateral order doctrine. View "Graber v. Boresky" on Justia Law

Petitioner pled guilty to a charge of lewd or lascivious conduct and was sentenced to five years of sexual offender probation. The terms of that probation provided that he “qualified and shall register with the Florida Department of Law Enforcement as a sexual offender pursuant to Section 943.0435.” Petitioner—proceeding pro se—sought federal habeas corpus relief from his conviction pursuant to Section 2254. The state moved to dismiss the petition for lack of jurisdiction because he was not “in custody” under Section 2254(a). The state argued that Petitioner was not in its physical custody at the time he filed his petition. Petitioner responded that his lifetime sex offender registration, “along with all the other restrictions that come with being a registered sex offender,” significantly restrained his individual liberty such that he was “in custody” for purposes of Section 2254(a). The district court dismissed Petitioner’s Section  2254 petition for lack of jurisdiction.   The Eleventh Circuit affirmed. The court found that Florida’s registration and reporting requirements for sex offenders do not render those offenders “in custody” within the meaning of Section 2254(a). The court reasoned that the proper inquiry here is under Jones v. Cunningham, 371 U.S. 236 (1963) and its progeny. First, he is not at the beck and call of state officials. Second, Petitioner is not required to live in a certain community or home and does not need permission to hold a job or drive a car. Third, Petitioner has to provide in-person advance notice of trips outside the state and outside the country, but the trips themselves do not require permission or approval by state officials. View "Louis Matthew Clements v. State of Florida, et al." on Justia Law

In 1985, two people were shot to death in rural Garrard County. Haight, who had escaped from jail days earlier, was captured in a nearby cornfield. During a chase, police discovered the victims’ possessions and both handguns used to commit the murders in a stolen truck abandoned by Haight. Haight pled guilty in exchange for the prosecutor’s recommendation of a life sentence without parole for 25 years. The court accepted Haight’s plea but sentenced him to death. The Kentucky Supreme Court vacated. Haight unsuccessfully sought specific enforcement of the plea agreement, was allowed to withdraw his plea, and went to trial. Haight admitted to the murders from the witness stand, claiming that he was suffering from “extreme emotional disturbance” and intoxication. The jury found him guilty of two counts each of intentional murder and first-degree robbery, and possession of a firearm by a convicted felon. Haight’s convictions and death sentence were affirmed. Haight was denied postconviction relief without discovery or an evidentiary hearing.In 2002, Haight sought habeas relief. The district court stayed the federal action. The Kentucky Court of Appeals and Kentucky Supreme Court refused to consider his unexhausted issues. Haight successfully moved to have the now-exhausted issues included in his amended 28 U.S.C. 2254 petition, which raised 45 grounds. Haight’s motion and application for the appointment of experts and his motion for discovery and an evidentiary hearing were denied.The Sixth Circuit affirmed the denial of relief, rejecting claims of ineffective assistance; upholding the refusals to permit the defense to have Haight examined by a neuropsychologist before sentencing and to appoint medical experts; rejecting challenges to jury instructions and to the exclusion of certain potential jurors; and rejecting arguments concerning the refusal to enforce the plea agreement. Kentucky’s death penalty statute is not facially unconstitutional. View "Haight v. Jordan" on Justia Law

Helphenstine was arrested for drug offenses on April 14 and taken to jail. Around 8:30 p.m. on Sunday, April 16, Helphenstine vomited and was moved to a “detox” cell. A local doctor was contractually obligated to visit the jail once a week. He came on Tuesday nights. Helphenstine’s condition deteriorated. Knowing that the office was closed, deputies faxed the doctor a non-emergency medical request, stating Helphenstine was vomiting and soiling himself, refusing to eat or drink, and had not gotten out of bed for 24 hours. The doctor testified he called the jail and directed that Helphenstine be taken to a hospital but was told that Helphenstine refused. There is no record of these calls. The doctor faxed prescriptions for antiemetics; although it was a Tuesday and although he knew of Helphenstine’s condition, he did not visit the jail. Around midnight, Helphenstine laid on his mat, where he remained. Around 3:30 a.m., Helphenstine was unresponsive; jailers began CPR and called 911. Helphenstine was pronounced dead en route to the hospital.Plaintiff’s experts testified that Helphenstine died either from withdrawal or from severe dehydration caused by withdrawal. Helphenstine’s death certificate lists his cause of death as “acute (fentanyl) and chronic drug abuse,” with the interval between onset and death listed as 6 minutes; fentanyl was present in Helphenstine’s blood. The district court rejected a deliberate indifference claim under 42 U.S.C. 1983. The Sixth Circuit reversed in part. A jury could conclude that Helphenstine’s death was the result of deliberate indifference by the county and the doctor; the individual defendants are not entitled to qualified immunity. View "Helphenstine v. Lewis County" on Justia Law

The Supreme Court affirmed the order of the circuit court entering judgment upon a jury verdict finding Defendant guilty of rape and sentencing him to life in prison, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the State intentionally circumvented his right to confront vital witnesses by improperly allowing into evidence a surreptitious recording made by Defendant's roommate and that the recording contained inadmissible hearsay. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the rape conviction; and (2) the circuit court did not err in admitting the recording into evidence. View "Wallace v. State" on Justia Law

The Court of Appeals reversed Defendant's conviction of one count each of attempted assault in the first degree and assault in the second degree and two counts of criminal contempt, holding that the trial judge committed constitutional error by ordering Defendant handcuffed without placing the special need for such restraints on the record and that the error was not harmless.The trial judge ordered Defendant to be handcuffed when the jury returned to announce its verdict. The judge, however, did not provide an on-the-record, individualized explanation for the restraints. The appellate division affirmed, concluding that any error in Defendant's being handcuffed without any explanation on the record was harmless. The Court of Appeals reversed, holding (1) until the jury returns to the courtroom, publicly announces the verdict and confirms the verdict, the defendant is still presumed innocent and the constitutional prohibition on restraining a defendant without explanation remains in force; and (2) the constitutional error in this case was not harmless beyond a reasonable doubt, requiring a new trial. View "People v. Sanders" on Justia Law

Plaintiffs were held in civil contempt and sentenced to incarceration for not paying child support. They challenged Lackawanna County’s policy of conditioning incarcerated civil contemnor child support debtors’ access to regularly paid work release on first working for half of their sentences sorting through trash at its Recycling Center, in purportedly dangerous and disgusting conditions, for five dollars per day, nominally as “community service.”Because the suit followed state suits in which the plaintiffs were found to be in contempt, the Third Circuit first addressed Rooker-Feldman, issue preclusion, and changed circumstances. The court affirmed the dismissal of the Thirteenth Amendment and Pennsylvania Wage Payment and Collection Law claims in full, and of the Trafficking Victims Protection Act (TVPA), 18 U.S.C. 1589, and Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1962(c), 1964(c) claims against the owners of the corporation that owns the recycling center. The court reversed the dismissal of the TVPA claims against the county, the Solid Waste Authority, and the corporation, the RICO claims against the corporation, the Fair Labor Standards Act, 29 U.S.C. 206(a)(1)(c), and Pennsylvania Minimum Wage Act claims against the county, the Authority, and the corporation, and their unjust enrichment claims against the county, the Authority, and the corporation. View "Burrell v. Staff" on Justia Law