Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of taking a controlled substance into a jail, a felony, and misdemeanor possession of a controlled substance, holding that there was no error in the convictions but remand was required for the limited purpose of correcting the written judgment and sentence.Specifically, the Supreme Court held (1) the evidence was sufficient for the jury to convict Defendant of voluntarily taking a controlled substance into a jail; (2) the evidence was sufficient for the jury to convict Defendant of knowingly possessing a controlled substance; and (3) this Court will not consider Defendant's constitutional claim because it was unpreserved and was not supported by relevant authority or cogent argument. View "Borja v. State" on Justia Law

While in jail, Plaintiff clawed at his own eye with enough force to tear it out. Plaintiff sued nearly everyone involved, including St. Charles County, under 42 U.S.C. Section 1983. The district court concluded that none of the individuals involved had violated his Fourth, Eighth, or Fourteenth Amendment rights. Nor, in the absence of a constitutional violation or a county-wide custom of unconstitutional conduct, was St. Charles County liable for his injuries. The question is whether qualified immunity is available to those who may have prevented the injury.   The Eighth Circuit affirmed the district court’s judgment. The court explained that the record is devoid of evidence that the Officer and Sergeant consciously disregarded a serious medical need. And even if the Nurse’s failure to administer Plaintiff’s medications approached criminal recklessness, the court wrote, it cannot say that the law was so “clearly established” that she was on “fair notice” she was violating it. Further, Plaintiff cannot point to any court that has held that an officer was deliberately indifferent because he placed a pepper-sprayed inmate in a new cell with a sink. View "Jamie Leonard v. Steven Harris" on Justia Law

The Supreme Court held that a claimant alleging wrongful imprisonment against state government entities and employees may not maintain such a suit once the claimant has received Tim Cole Act compensation through the state administrative process.Plaintiff was imprisoned for about twelve years, most of them on death row, until his conviction was vacated on the ground that the prosecutor had failed to disclose exculpatory evidence during his criminal trial. Plaintiff brought suit in federal court under 42 U.S.C. 1983, alleging that various state government entities and employees had violated his constitutional rights. Based on the results of an independent investigation, the district court dismissed Plaintiff's charges on the grounds that Plaintiff was actually innocent. Plaintiff was subsequently granted compensation under the Tim Cole Act. The district court granted Defendants' motion to dismiss Plaintiff's federal case, concluding that Plaintiff's recent of compensation from the state foreclosed his suit. On appeal, the federal district court certified a question to the Supreme Court. The Supreme Court answered that Plaintiff's acceptance of the Tim Cole Act compensation barred maintenance of this lawsuit. View "Brown v. City of Houston, Texas" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Defendant and dismissing Plaintiff's claim that Iowa's tax-sale statute violates due process because it doesn't require personal service of a written notice that the taxpayer will lose his or her land, holding that the court did not err.Plaintiff stopped paying property taxes on a parcel of farm land he obtained, and the parcel was sold at a tax sale. Defendant paid Defendant's overdue taxes and received a certificate of purchase. When Plaintiff did not redeem the parcel Defendant sent Plaintiff notice by regular mail and certified mail to the parcel itself and to Plaintiff's last known address. After ninety days the county treasurer issued a tax sale deed to Defendant. Plaintiff brought this action claiming he did not timely receive actual notice of the tax sale proceedings and that Iowa Code 447 violates constitutional due process guarantees because it does not require effective notice. The district court granted summary judgment for Defendant. The Supreme Court affirmed, holding that Plaintiff failed to show a due process violation in this case. View "Kluender v. Plum Grove Investments, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for voluntary manslaughter, holding that the circuit court committed no instructional error or constitutional violation in the underlying proceedings.On appeal, Defendant argued, among other things, that the district court erred in instructing the jury on a "stand your ground" defense, which confused the jury about his actual justification defense. The Supreme Court affirmed, holding (1) Defendant was not entitled to relief on his argument that the stand-your-ground defense wasn't in play, and thus that the stand-your-ground instruction was erroneously given; and (2) including the term "illegal activity" in the instructions did not violate Defendant's right to due process. View "State v. Ellison" on Justia Law

Plaintiff protested outside the federal courthouse in Portland, Oregon. He alleged that federal officers unlawfully arrested protesters and used excessive force, including by indiscriminately using tear gas against peaceful protesters. Together with other protesters, he brought this action against Defendant, then the Director of the Federal Protective Service’s Northwest Region, under Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971). The district court denied Defendant’s motion to dismiss.   The Ninth Circuit reversed, concluding that no Bivens cause of action is available in this case. Applying the two-step analysis set forth in Egbert v. Boule, 142 S. Ct. 1793 (2022), the panel held that a Bivens remedy could not be extended to this case because it presented a new context, and at least two independent factors indicated that the court was less equipped than Congress to determine whether the damages action should proceed.   The court wrote this case differed from Bivens because (1) Defendant, a high-level supervisor, was of a different rank than the agents in Bivens; (2) Defendant’s alleged actions, which consisted of ordering or acquiescing in unconstitutional conduct, took place at a higher level of generality than the actions of the agents in Bivens; and (3) the legal mandate under which Defendant acted differed from that of the agents in Bivens in that Defendant was directing a multi-agency operation to protect federal property and was carrying out an executive order. Allowing a Bivens action to proceed in this case could expose sensitive communications between Defendant and other high-level executive officers. View "MARK PETTIBONE, ET AL V. GABRIEL RUSSELL, ET AL" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first-degree rape and two counts of sexual contact with a child under the age of sixteen, holding that Defendant was not entitled to relief on his claims of error.After a jury trial, Defendant was found guilty of rape and sexual contact with a minor and sentenced to two consecutive sixty-year terms of imprisonment on the rape convictions. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant's motion for judgment of acquittal on the two rape charges; (2) the submission of the sexual contact charges to the jury did not violate the prohibition against double jeopardy; (3) there was no improper bolstering of witnesses at trial by either the circuit court or the prosecution; (4) the circuit court did not abuse its discretion by denying Defendant's motion for a new trial; (5) Defendant's sentence neither violated the constitutional prohibition against cruel and unusual punishment, nor did it constitute an abuse of discretion; and (6) no other prejudicial error occurred. View "State v. Manning" on Justia Law

Officers in an armored police vehicle shot tear gas at three people near the scene of a protest in downtown St. Louis. The district court concluded that all three had a First Amendment retaliation claim.   The Eighth Circuit affirmed in part, reversed in part, and remanded. The court agreed that one Plaintiff has a valid First Amendment retaliation claim, but qualified immunity shields the officers from the claims brought by the others. Two of the Plaintiffs claimed that the First Amendment covers what they did, which was to observe and record police conduct during the St. Louis protest. The court wrote that even if it were to assume they are correct, observing and recording police-citizen interactions was not a clearly established First Amendment right in 2015. Further, in regard to Plaintiffs’ peaceful-assembly theory. The court reasoned even if the officers “unreasonably believed” that the group was refusing to comply with their earlier directions to disperse, their official orders—not retaliatory animus—caused them to use the tear gas.   However, in regard to the third Plaintiff, the court explained at this stage, there is enough evidence to establish the “personal involvement” of everyone in the armored vehicle. To be sure, Plaintiff could not see who launched the tear gas canister. But with multiple “officers present,” the jury could find that each one of them participated in the decision or that one did it “while the others failed to intervene.” Under these circumstances, the claims against the individual officers can proceed. View "Sarah Molina v. Daniel Book" on Justia Law

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