Justia Civil Rights Opinion Summaries

In 1993, Clark entered Catlin's Galesburg apartment to commit robbery. Clark was 24 years old; Catlin was 89. Clark killed Catlin by cutting her throat, then robbed the apartment. Clark pled guilty but mentally ill to first-degree murder and robbery. Clark suffered from antisocial personality disorder, borderline personality disorder, and fetal alcohol syndrome. He had an IQ of 79 and the intellectual ability of a 13-14-year-old; he had been severely abused as a child and had an extensive criminal history. Clark was sentenced to 90 years of imprisonment for the murder, with a consecutive 15-year prison sentence for the robbery. The appellate court affirmed. In 2001 and 2012 Clark filed unsuccessful post-conviction petitions.In a 2018 motion for leave to file a successive postconviction petition, Clark challenged the constitutionality of his sentence as inconsistent with the Illinois Constitution's proportionate penalties clause. Clark argued that his sentence was the functional equivalent of a life sentence and that the circuit court failed to give sufficient weight to the characteristics of his intellectual disabilities and his young age as mitigation factors. The appellate court and Illinois Supreme Court affirmed the denial of relief.The proportionate penalties clause requires penalties to be determined with the objective of restoring the offender to useful citizenship and provides a limitation on penalties beyond those afforded by the eighth amendment. Precedent does not establish “cause” for relaxing the res judicata doctrine with respect to the issues Clark raised, which were decided on direct appeal. Clark also cannot establish prejudice under the cause-and-prejudice test by advancing a challenge to his sentence as it relates to his intellectual disabilities. “Neurological development was not a prospect for” Clark. View "People v. Clark" on Justia Law

Plaintiff had three possible strikes: one dismissal for failure to state a claim, another dismissal for failure to exhaust administrative remedies, and a summary judgment for failure to exhaust. The first dismissal is a strike because the dismissing court expressly said it was dismissing the action for failure to state a claim. At issue was whether: (1) “Is a dismissal for failure to exhaust administrative remedies a ‘strike’ for purposes of the Prison Litigation Reform Act?”; and (2) “If a dismissal for failure to exhaust administrative remedies can be a ‘strike’ for purposes of the [Act]’s ‘three strikes’ provision, does Wells have three strikes?”   The Eleventh Circuit reversed the dismissal of Plaintiff’s complaint based on the three-strikes rule and remanded for further proceedings. The court explained that it agreed with the district court that the second dismissal—for failure to exhaust—counted as a strike because the dismissing court gave some signal in its order that the action was dismissed as frivolous, malicious, or for failure to state a claim. But the court agreed with Plaintiff that the summary judgment for failure to exhaust was not a strike because it was not a dismissal for failure to state a claim. Thus, without three strikes, the district court erred in dismissing Plaintiff’s complaint under the three-strikes rule. View "Jeremy John Wells v. Warden, et al" on Justia Law

A North Carolina social services department received a tip that Michael had engaged in inappropriate sexual contact with his four-year-old stepdaughter. Michael and his family subsequently moved to Kentucky, where Family Services told detectives that Michael was possibly sexually abusing the children. All three children were placed into foster care.Before each interview, Michael received and waived his Miranda rights. He admitted to touching “between [Dorothy’s] legs and in her vagina area.” The detectives later said: “You’re going to continue to not have any contact with your children just until you admit to everything.” Michael said that he’d “like to talk to a therapist or something other than social services.” The detectives continued, saying: “You’re going to continue the rest your [sic] life without seeing your children because you want to bottle this up.” During a second interview, Michael admitted to multiple acts of sexual abuse that he had previously denied.Michael unsuccessfully moved to suppress the incriminating statements as coerced under “Miranda.” The Kentucky Supreme Court found that four of the officers’ statements “were delivered in a threatening manner” but noted that Michael had already admitted to three instances of sexual abuse. That court, the federal district court, and the Sixth Circuit affirmed the denial of the motion to suppress. The Kentucky Supreme Court’s decision did not involve an unreasonable determination of the facts or an unreasonable application of clearly established federal law. View "Michael v. Butts" on Justia Law

While investigating a heroin distribution network involving Triplett and Collins, investigators obtained court-authorized wiretaps on 12 phones, 18 U.S.C. 2510. In copying files containing the recordings onto optical discs and sealing those discs, the government made mistakes, failing to seal the Phone 5 recordings and those from nine days on Phone 9. The government searched Collins's stash house, and recovered heroin, cutting agents, packaging, and 10 firearms.After the government disclosed its Phone 9 mistake, Collins moved to suppress those recordings and all subsequent recordings which relied on the improperly sealed disks to obtain additional authorizations. The government committed not to use at trial any Phone 9 recordings from the nine-day unsealed period. The district court denied the motion, finding that no later wiretap applications relied on unsealed recordings.The government later discovered and disclosed the Phone 5 error. Collins filed another motion to suppress. The government agreed not to use any Phone 5 recordings at trial but opposed the suppression of recordings from other phones. The district court denied the motion, finding that the government had not yet failed to immediately seal Phone 5 when it applied for another wiretap, that the government’s explanation concerning mechanical error was satisfactory, and that the applications for additional wiretaps did not rely on the recordings. Collins pleaded guilty to conspiracy, firearm, and money laundering offenses.The Seventh Circuit affirmed. The government’s voluntary suppression of the unsealed recordings indicated that they were not central to the case, which supported the government’s explanation. View "United States v. Collins" on Justia Law

Plaintiff Alive Church of the Nazarene, Inc. (the “Church”) purchased 17 acres of land — zoned primarily for agricultural use — on which the Church sought to conduct religious assemblies. After Defendant Prince William County, Virginia (the “County”), denied the Church’s request to worship on its property before the Church complied with the zoning requirements, the Church initiated a lawsuit in district court. By its Complaint, the Church has alleged six claims against the County — three claims under the Religious Land Use and Institutionalized Persons Act (“RLUIPA”), and three federal constitutional claims. For reasons explained in its Memorandum Opinion of November 2021, the district court dismissed those claims pursuant to Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief can be granted.   The Fourth Circuit affirmed. The court explained that allowing religious institutions to conduct worship services does not further the purpose of the Agricultural Zoning Ordinance — that is, to promote farming. Specific to the Church, allowing services would not increase its ability to continue farming its land. Accordingly, the court wrote it cannot agree with the Church that it is similarly situated to farm wineries and limited-license breweries with regard to the Ordinance. The Church has failed to meet its initial burden of proof by providing a similarly situated comparator with which it has been treated unequally, and has thereby failed to state an RLUIPA equal terms claim. View "Alive Church of the Nazarene, Inc. v. Prince William County, Virginia" on Justia Law

Plaintiff filed a 42 U.S.C. Section 1983 lawsuit stemming from her son’s death while under the supervision of employees at an Arkansas jail. She alleged that Defendants were deliberately indifferent to her son’s serious medical needs. The district court denied Defendants’ motion for summary judgment based on qualified immunity.   The Eighth Circuit reversed. The court explained that it disagreed with the district court’s opinion that a layperson would recognize seizure-like activity as a serious medical need that one of the Defendant’s deliberately ignored. The court reasoned that a reasonable jury could not conclude from this description of events that Defendant was aware of a serious medical need. Second, a reasonable officer would not necessarily infer that seizure-like activity in these circumstances required him to take additional action. The decedent was behaving normally at booking, though very thirsty and reportedly under the influence of methamphetamine. It isn't unreasonable to believe that whatever medical episode he experienced during transport (if he actually experienced one) had fully resolved itself by the time Defendant encountered him.   Further, the court explained that in these circumstances, Defendants can't be faulted for presuming that the medical staff best knows the quantity and quality of information needed for assessments. And even though the decedent was obviously sick, recognizing that someone is sick is not the same as knowing that he is receiving inadequate care from a trained medical professional. View "Donna Reece v. S. Williams" on Justia Law

Auto sears can be installed into semi-automatic guns to make them fully automatic. The National Firearms Act defines a machine gun as any gun that can shoot more than one shot “by a single function of the trigger,” 26 U.S.C. 5845(b). ATF decided in 1981 to define auto sears as machine guns, even if not installed or owned in conjunction with a compatible rifle. Ruling 81-4 brought auto sears under the Act’s regulatory scheme, which demands that all machine guns be registered. In 1986 the Gun Control Act was amended to make it unlawful for “any person to transfer or possess a machine gun,” 18 U.S.C. 922(o), effectively freezing the number of legal machine guns. Roe purchased his auto sear in 1979 and never registered it.In 2020 Roe sought to force the ATF either to exempt his auto sear from the registration requirements or to permit him to register it. Roe argued that under Ruling 81-4 auto sears that were already manufactured or possessed were exempted permanently from the Firearms Act's requirements. The ATF argued that the Ruling only refers to a retroactive exemption for taxes related to pre-1981 auto sears, that any now-unregistered auto sear is contraband, and that the 1986 machine gun ban means that there is no way to register an auto sear. The district court dismissed Roe’s complaint, reasoning that it lacked authority to issue the requested injunction, and noting that the constitutionality of the statutes had already been upheld. The Seventh Circuit affirmed, noting that the claim concerning the Ruling was untimely. Roe’s misinterpretation of Ruling 81-4 and his failure to recall that he owned the auto sear do not support relief. View "Roe v. Dettelbach" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony strangulation of a household member and misdemeanor false imprisonment, holding that the district court did not err or abuse its discretion in the proceedings below.On appeal, the Supreme Court held that the district court (1) did not err by concluding that the affidavit in support of the search warrant to search Defendant's cellular phones, his place of employment, his work truck, and his person for certain documents, including journals, established probable cause to search and seize Defendant's journals and in thus denying Defendant's motion to suppress; and (2) did not abuse its discretion at sentencing by considering conduct for which Defendant was acquitted. View "Kreusel v. State" on Justia Law

The Supreme Court reversed the district court's ruling granting Defendant's motion to suppress statements she made during a custodial interview, holding that some deception by law enforcement in this case did not exceed what the legal system tolerates.Defendant's husband died of strangulation after being zip-tied in a chair in his residence. Defendant claimed that her husband had tied himself up. During an interview at the police station, police officers told Defendant falsely that doctors were still working to save her husband's life. An hour and half into the interview the officers corrected their deception. The officers also made various reassurances and suggestions to the woman. The trial court granted Defendant's motion to suppress. The Supreme Court reversed, holding (1) the officers' lie about whether her husband had been pronounced dead did not affect Defendant's essentially knowing and voluntary waiver of her Miranda rights; and (2) the officers' expressions of sympathy did not amount either to express or implied promises of leniency that would create a fair risk of a false confession. View "State v. Park" on Justia Law

The Supreme Court affirmed Defendant's conviction for the first degree murder of Rafael Noriega and his sentence of death, holding that there was no reversible error in the proceedings below.A jury convicted Defendant of first degree murder and found true the special circumstance allegation that the murder was committed while Defendant was engaged in the commission of a robbery. The jury also found true the special circumstance allegation that Defendant was previously convicted of murder. The jury returned a verdict of death, and the trial court denied Defendant's ensuing motion for modification of his sentence. The Supreme Court affirmed, holding (1) the trial court did not deny Defendant's right to self-representation in its rulings regarding Defendant's funding requests; (2) there was no error or abuse of discretion in the district court's evidentiary rulings; (3) Defendant's challenges to the special service allegations were unavailing; (4) there was no error in the jury instructions; (5) there was no error or abuse of discretion during the penalty phase; and (6) Defendant's challenges to the constitutionality of California's death penalty law failed. View "People v. Thomas" on Justia Law