Justia Civil Rights Opinion Summaries

In 2021, Tennessee enacted a statute that vaccination, masking, and quarantine decisions: “A local health entity or official, mayor, governmental entity, or school does not have the authority to quarantine a person or private business for purposes of COVID-19,” and “a school or a governing body of a school shall not require a person to wear a face mask while on school property” unless various conditions are met. Before seeking accommodation under its terms, eight minor students with disabilities filed suit, alleging that the legislation violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101m Section 504 of the Rehabilitation Act, 29 U.S.C. 794, the Equal Protection Clause, and the Supremacy Clause. The district court granted a preliminary injunction with respect to sections of the Act concerning face coverings for schools and provisions that prohibit local health officials and schools from making quarantining decisions as they relate to public schools.While acknowledging that the case is moot, the Sixth Circuit dismissed it for lack of jurisdiction. The plaintiffs’ argument that they are injured because the Act categorically violates the ADA amounts to an overly generalized grievance. They do not seek redress for a completed violation of a legal right; they seek only prospective relief to protect against future violations. Their injuries are not fairly traceable to any defendant, so no remedy applicable to those defendants (be it an injunction or a declaration) would redress the alleged injuries. View "R. K. v. Lee" on Justia Law

Wellpath contracted with the jail to provide on-site medical staff and services. Wellpath assigned Dr. Cogswell, to work at the jail. While there, he sexually assaulted three inmates during their visits to the medical clinic. None of the women called out for help or otherwise indicated to the jail staff that anything untoward was occurring. One inmate, Bills recounted seeing an unidentified officer “glance through the little crack of the white curtain [and give] kind of like a head nod,” which Bills interpreted as the officer saying to Cogswell “I got your back.” Wellpath had a policy that if there was a sensitive exam going on, there would be a chaperone. During Cogswell’s tenure, Macomb Officer Horan reported to Wellpath’s nursing director and a Wellpath paramedic that Cogswell was potentially violating this policy by seeing patients unchaperoned, using a privacy screen. At Horan’s request, the nursing director “pop[ped] [her] head in” and saw “nothing out of the ordinary[ or] suspicious.”Days after their assaults, inmates reported the incidents to the jail. Wellpath learned of the reports the same day and immediately informed Cogswell not to report to work. Following an investigation, his employment was terminated. Cogswell was later convicted of second-degree criminal sexual conduct. In the inmates’ suit under 42 U.S.C. 1983, the Sixth Circuit affirmed summary judgment in favor of the defendants, citing the lack of evidence that the defendants knew of Cogswell’s assaults before they were reported. View "Buetenmiller v. Macomb County Jail" on Justia Law

The Supreme Court affirmed the order of the circuit court resentencing Petitioner, for purposes of this appeal, to an aggregate term of incarceration of five to twenty-five years for her convictions for child neglect resulting in death and gross child neglect creating a risk of substantial injury or death, holding that Petitioner was not entitled to relief.On appeal, Petitioner argued that the circuit court violated her right under the Sixth Amendment to conflict-free counsel and that the State violated Brady v. Maryland, 373 U.S. 83 (1963), by failing to disclose certain records. The Supreme Court disagreed and affirmed, holding (1) the trial court did not err in finding that even if counsel's performance was deficient, the deficient performance did not adversely affect the outcome of the trial; and (2) there was no merit in Petitioner's contention that a Brady violation occurred in this case. View "State v. A.B." on Justia Law

Respondent has long struggled with mental illness and a proclivity to violent outbursts. In 2017, Williams assaulted a security guard in Portland, Oregon—a federal crime because it happened at a Social Security office. Respondent pleaded guilty and was sentenced to just over four years in prison, to be followed by three years of supervised release. Federal prisoners on the cusp of being released may be civilly committed if they are “presently suffering from a mental disease or defect as a result of which [their] release would create a substantial risk” to the person or property of others. Here, the primary question is whether—in making such a risk assessment—a court must consider any terms of supervision that would govern the prisoner’s conduct post-release.   The Fourth Circuit held that a court must consider any terms of supervision that would govern the prisoner’s conduct post-release. Thus, because the record offers no assurances the district court appropriately considered the terms of Respondent’s supervised release before ordering him committed, the Fourth Circuit vacated the district court’s order and remanded for further proceedings. View "US v. Nathaniel Williams" on Justia Law

In this petition for an extraordinary writ the Supreme Court held that when probable cause has been found after a preliminary hearing but the case is dismissed without prejudice due to a defect in the prosecution, Haw. R. Pen. P. 12(g) permits a court to hold a defendant in custody or continue bail for a specified time that is reasonable under the circumstances.After the court dismissed charges against Scott Deangelo, it ordered under Rule 12(g) that Deangelo remain in custody for ninety days while the State sought a grand jury indictment. Deangelo brought this challenge to Rule 12(g), arguing that it violates the Fourth Amendment to the United States Constitution and Haw. Rev. Stat. 803-9(5), which requires an arrested person to be taken before a qualified magistrate for examination within forty-eight hours of arrest. The Supreme Court held that Rule 12(g) is constitutional and that the time specified must be reasonable in light of all of the circumstances. View "Deangelo v. Souza" on Justia Law

Plaintiffs, who identify as Moorish Americans, sought to enter the Caddo Parish Courthouse to file documents with the court clerk. Upon arriving at the security-screening station, plaintiffs informed the officers on duty that they wished to enter without passing through the security screening. After Plaintiffs’ repeated refusals to depart, the officers stated they would count to three and, if Plaintiffs refused to leave, they would be arrested. They did not depart and were arrested, charged with violating Louisiana Revised Statutes Section 14:63.3.Plaintiffs brought a litany of claims against various officials serving in Caddo Parish and the Louisiana state government based on their actions taken during the arrest. Plaintiffs also moved for recusal of the magistrate judge, which the district court denied.   The Fifth Circuit affirmed. The court explained that Plaintiffs have pointed to no precedent that abrogates the general “search incident to arrest” rule when religious headwear is involved. Accordingly, the district court correctly granted summary judgment on the ground of qualified immunity. Further, the court held that there was no error in the district court’s denial of Plaintiffs’ motion for recusal of the magistrate judge. The magistrate judge did not work on this case in private practice nor work with Defendants’ counsel in the practice of law while he was working on this case. Nor is there evidence of any bias or knowledge of the case that would have required the district court, in its discretion, to order recusal. View "Foley Bey v. Prator" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and his corresponding death sentence, as well as Defendant's conviction for conspiracy to commit murder, holding that Defendant was not entitled to relief on any of his allegations of error.On appeal, Defendant raised numerous challenges to his convictions and death sentences. The Supreme Court affirmed the judgment in its entirety, holding (1) there was no merit to Defendant's arguments regarding the guilt phase of his trial; and (2) Defendant's claims regarding the penalty phase of his trial were also without merit. View "Sievers v. State" on Justia Law

Illinois State Police Officer Myers supervised 10 controlled drug purchases by a confidential source (CS) at a Cairo residence. Each purchase was recorded on video. The CS initially said that “Cornelius Dean” was selling crack cocaine at the house. Eventually, the CS found out the dealer’s name was Ed. Ed later told the CS that his surname was “Johnson.” Myers searched for an image of an “Ed or Edward Johnson” in the Illinois Secretary of State database but found no match. Alexander County Sheriff Brown suggested Ed’s last name might be Osborne. Myers again checked the state database and discovered that “Phillip Edward Osborne” resided in Cairo. Myers obtained Osborne’s driver’s license photo and concluded that it matched the dealer in the drug buy videos. Myers reported that the CS, upon seeing the photo, unequivocally, identified Osborne. Myers obtained an arrest warrant. Osborne was arrested and remained incarcerated for seven days before being released on bond. The state eventually dismissed the charges.Osborne sued under 42 U.S.C. 1983. The district court dismissed the claims against the county and granted Myers summary judgment on the false arrest claim, finding no evidence to undermine probable cause to arrest Osborne and that Myers was entitled to qualified immunity. The Seventh Circuit affirmed. The plaintiff failed to overcome the presumption of validity accorded to the warrant and the underlying information, with little more than bare allegations that Myers lied in his warrant application. View "Johnson v. Myers" on Justia Law

In 2019, Tennessee imposed new requirements for conducting voter-registration activities. The law required individuals to register with the state; complete state-administered “training”; file a “sworn statement” agreeing to obey Tennessee’s voter-registration laws; and return “completed” voter-registration forms within 10 days. Plaintiffs argued that the law significantly burdened their rights of speech and association, in violation of the First Amendment, and was unconstitutionally vague. The court stated that the defendants had offered “little, if any, evidence” in support of the Act’s requirements, “despite having had an opportunity” and held that the plaintiffs were likely to prevail on the merits, further noting “the vagueness about the scope and nature" of the Act. The court “ordered” the defendants “not to take any steps to implement” or otherwise enforce the challenged provisions. The defendants did not appeal. Seven months later, the state repealed the provisions.The district court approved a stipulation to dismiss the case without prejudice. Plaintiffs were awarded attorneys’ fees under 42 U.S.C. 1988, as the “prevailing party.” The Sixth Circuit affirmed. A preliminary injunction that, as a practical matter, concludes the litigation in the plaintiffs’ favor and that is not challenged on appeal, is, in this case, enduring enough to support prevailing-party status under section 1988. View "Tennessee State Conference of the NAACP v. Hargett" on Justia Law

In 1995, Range pleaded guilty to making false statements about his income to obtain $2,458 of food stamp assistance in violation of Pennsylvania law, a conviction that was classified as a misdemeanor punishable by up to five years’ imprisonment. Range was sentenced to three years’ probation, plus restitution, costs, and fines. Three years later, Range attempted to purchase a firearm but was rejected by the instant background check system. Range’s wife subsequently bought him a deer-hunting rifle. Years, later Range learned that he was barred from purchasing and possessing firearms because of his welfare fraud conviction. He sold his rifle to a firearms dealer and sought a declaratory judgment that 18 U.S.C. 922(g) violated the Second Amendment as applied to him. The section prohibits firearm ownership by any person who has been convicted of a crime punishable by imprisonment for a term exceeding one year—the federal definition of a felony.The district court rejected the suit, holding that the Second Amendment does not protect “unvirtuous citizens.” The Third Circuit affirmed. Based on history and tradition, “the people” constitutionally entitled to bear arms are “law-abiding, responsible citizens,” a category that properly excludes those who have demonstrated disregard for the rule of law through the commission of felony and felony-equivalent offenses, whether or not those crimes are violent. Even if Range fell within “the people,” the government demonstrated that its prohibition is consistent with historical tradition. View "Range v. Attorney General United States" on Justia Law