Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court holding that International Paper Co. had established, by a preponderance of the evidence, that the County of Isle of Wight's tax scheme violated the requirement of the Virginia Constitution that taxation be uniform, holding that the circuit court did not err.In 2017, the County Board of Supervisors adopted a resolution authorizing an "economic development retention grant program" that would benefit certain taxpayers. International Paper filed a refund action alleging that the County's tax and retention grant scheme violated the uniformity requirement of the Virginia Constitution. The circuit court granted judgment in favor of International Paper, concluding that the County's tax scheme created an unconstitutional non-uniform tax. View "County of Isle of Wight v. International Paper Co." on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress the fentanyl discovered in his waistband during a pat-frisk conducted after an anonymous tip alerted the police department of two men passed out in a vehicle, holding that there was no error.In denying Defendant's motion to suppress, the district court concluded that the investigatory stop did not violate Defendant's Fourth Amendment rights and that the officers had reasonable suspicion that Defendant could have been armed with a weapon to justify a Terry frisk. The First Circuit affirmed, holding that there was no Fourth Amendment violation because the arresting officer had reasonable suspicion for the initial encounter, for extending the stop, and to believe Defendant was armed and dangerous. View "United States v. Harrington" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress evidence collected during the investigation that led to his arrest, holding that the district court did not err in denying Defendant's motion to suppress.Defendant pled guilty to one count of sexual exploitation of a minor. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence discovered after agents executed a warrant to search his residence. The First Circuit affirmed, holding (1) the warrant's affidavit established a sufficient nexus between the criminal activity and the places to be searched; (2) the district court reasonably found that no search of Defendant's person occurred; and (3) the district court did not err in denying Defendant's statements to law enforcement agents. View "United States v. Corleto" on Justia Law

Ross was charged with battery on a nonconfined person by a prisoner. Ross pleaded guilty to the administrative charge of battering the counselor. At trial, several officers and an intercepted letter corroborated the victim’s testimony about the attack. The defense presented no evidence. During discussions about jury instructions, Ross declared, “Man, you are fired” and “I will represent myself.” Ross cursed at the court, which had him removed. Defense attorney Fallman stated that he tried to talk with Ross, who refused and declined to return to the courtroom. Fallman noted that Ross had fired his previous attorney and that he knew of no “provocation.” The court continued without Ross. During closing arguments, Fallman admitted Ross touched the officer willingly, in a harmful or offensive manner, but argued there was no preplanning or weapon. Fallman asked the jury to find Ross guilty of the lesser included offense of misdemeanor battery. The jury convicted Ross, finding two prior strike allegations true. Finding six aggravating factors true and no mitigating factors, the court sentenced Ross to the upper term of four years, doubled to eight years under the Three Strike Law.The court of appeal affirmed the conviction, rejecting Ross’s argument that his attorney violated his Sixth Amendment rights by conceding his guilt. There was no evidence that his claimed desire to maintain innocence to the exclusion of all other defense strategies was ever communicated to Fallman or the court. The court remanded for resentencing due to Senate Bill 567., which requires that when a statute specifies three potential terms of imprisonment, a court must presumptively impose the middle term. View "People v. Ross" on Justia Law

Stapleton lured women into prostitution and exploited them using threats, force, and other forms of coercion. An anonymous tip led to his arrest. Indicted for sex-trafficking crimes, Stapleton claimed that the police had fabricated the anonymous tip and tampered with his cellphone. The court appointed a succession of defense attorneys, but Stapleton constantly disagreed with them regarding his police-misconduct claims. The judge denied his motion to suppress the evidence derived from the anonymous tip. Stapleton then insisted on representing himself. After making the inquiries required by Supreme Court precedent, the judge granted Stapleton’s motion and appointed a standby attorney. Before trial, Stapleton unsuccessfully moved for a court-funded expert to investigate his phone-tampering claim. Before opening statements, Stapleton announced that he would conditionally plead guilty, reserving the right to challenge the suppression ruling. The judge conducted a colloquy and accepted Stapleton’s pleas. Before sentencing, Stapleton unsuccessfully moved to withdraw his pleas. The judge sentenced him to life in prison.Stapleton did not appeal the suppression ruling but argued that his guilty pleas were invalid because he did not have counsel and was confused about his appellate rights and challenged the denial of his motion for a court-funded expert. The Seventh Circuit affirmed. Stapleton validly waived his right to counsel after two thorough colloquies; his guilty pleas were also knowing and voluntary. The judge did not abuse his discretion in denying Stapleton’s request for a court-funded cellphone expert. View "United States v. Stapleton" on Justia Law

This case concerns a public high school’s ability under the First Amendment to discipline students for assertedly “private” off-campus social media posts that, once they predictably made their way onto campus, amounted to “severe bullying or harassment targeting particular” classmates.   The Ninth Circuit affirmed the district court’s judgment rejecting First Amendment claims brought by students against Albany High School and school officials after the students were disciplined for assertedly “private” off-campus social media posts that amounted to severe bullying or harassment targeting particular classmates. The panel held that, under the circumstances of the case, the school properly disciplined two of the involved students for bullying. The court explained that some of the posts used violent imagery that, even if subjectively intended only as immature attempts at malign comedy, would reasonably be viewed as alarming, both to the students targeted in such violently-themed posts and to the school community more generally. Nothing in the First Amendment would even remotely require schools to tolerate such behavior or speech that occurred under its auspices.   The panel concluded, taking into account the Supreme Court’s recent decision in Mahoney Area Sch. Dist. v. B.L. ex rel. Levy, 141 S. Ct. 2038 (2021), that the speech bore a sufficient nexus to Albany High School and its students to be susceptible to regulation by the school. Finally, the panel concluded that the discipline did not independently violate the California Constitution or the California Education Code. Because California follows federal law for free expression claims arising in a school setting, Plaintiffs’ reliance on the California Constitution failed for the same reasons discussed above. View "KEVIN CHEN, ET AL V. ALBANY UNIFIED SCHOOL DISTRICT, ET AL" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree premeditated murder, attempted first-degree murder, and kidnapping, holding that there was no error in the proceedings below.On appeal, Defendant argued, among other things, that the district court erroneously joined his and his codefendant's cases for trial and by denying subsequent severance motions. The Supreme Court affirmed his convictions, holding (1) the district court did not improperly join Defendant's and his codefendant's cases for trial and did not erroneously refuse to sever the cases once the trial was underway; (2) the prosecutor did not commit misconduct during closing arguments; and (3) Defendant was not entitled to relief as to the claims he raised in a pro se supplemental brief. View "State v. Davis" on Justia Law

Appellants, three Sikh men, intended to join the Marines. However, existing Marines pre-enlistment requirements pertaining to hair length, beards, and a prohibition on wearing certain non-uniform items, conflicted with their faith. The Marines allowed an accommodation, but only after the men completed basic training.Appellants sought a preliminary injunction, and the district court refused. After considering the competing interests in the case, the D.C. Circuit reversed the decision as it related to two men, finding that they showed a likelihood for success on the merits and proved irreparable harm. The court remanded the third man's case for further proceedings. View "Jaskirat Singh v. David Berger" on Justia Law

M.G. was detained in August 2022 for the 14-day confinement allowed by Welfare and Institutions Code section 5250 (Lanterman-Petris-Short Act). The 14-day period was set to expire September 4. On August 26, a Friday, M.G. sought habeas relief ordering her release, arguing that she was not mentally disordered, gravely disabled, or a danger to anyone. A hearing was set for the following Tuesday, August 30. M.G. is hearing impaired; she requested two sign language interpreters: an ASL interpreter and a certified deaf interpreter. Relay interpreting using both interpreters was necessary for M.G. to understand the proceedings and communicate with counsel. On Tuesday, the court informed the parties that neither interpreter was available that day. The hearing was continued to Thursday, September 1. On August 31, M.G. petitioned the appeal court.After the court issued an order to show cause, counsel indicated M.G. had been released. Unable to grant the relief requested—release from confinement—the court denied her petition as moot, noting that temporary confinement can last at most 14 days, so a challenge to its propriety will routinely evade appellate review. Welfare and Institutions Code 5276 imposes a mandatory duty to conduct an evidentiary hearing within two judicial days of a detained person’s request; failure to do so requires that the detainee be immediately released. View "In re M.G." on Justia Law

The Humboldt County Department of Health and Human Services filed a petition alleging that the minor had been sexually abused by her father. Mother was not named as an offending parent in the petition. The juvenile court found that the Department failed to prove the sexual abuse allegations against the father but did not dismiss the petition. Instead, the court found that the evidence supported jurisdiction based upon unpleaded allegations of emotional abuse by the mother, a position urged by the minor’s counsel but opposed by the Department. The court subsequently entered a disposition order.The court of appeal reversed. The juvenile court violated the mother’s due process rights when it established jurisdiction based on the conduct of a parent the Department never alleged was an offending parent, and on a factual and legal theory not raised in the Department’s petition. Parents have a due process right to be informed of the nature of the proceedings and the allegations upon which the deprivation of custody is predicated so that they can make an informed decision on whether to appear, prepare, and contest the allegations. View "In re S.V." on Justia Law