Justia Civil Rights Opinion Summaries

The Cincinnati Citizen Complaint Authority investigates alleged police misconduct and usually interviews the relevant officers, complainants, and other witnesses. Officers are required to participate in such investigations. An officer may bring a union representative to the interview. The Authority video records the interviews. Sergeant Hils, the President of the Union, claims that Authority Investigator Ekeke, in recording an officer’s interview, selectively turned off the recording when the officer made exculpatory statements. Another time, he alleges, Ekeke “threatened” an officer before the interview. Hils tried to record an interview of Officer Knapp, whom he represented. The Authority instituted a policy, prohibiting officers or their representatives from recording the interviews.Hils and affected officers sued, alleging violations of their free-speech rights, 42 U.S.C. 1983. The union filed an unfair labor practices charge, which led to a partial settlement agreement. The city agreed to record all future interviews. The district court held that the settlement agreement mooted the selective-recording claims and that the First Amendment does not include a right to record a government investigation. The Sixth Circuit affirmed. The policy satisfies rational-basis review. The Authority has legitimate interests in maintaining order and fairness during its interviews by ensuring the ongoing interviews are not selectively broadcasted, by ensuring the integrity of the investigation, by protecting the subjects of the investigation from unfair and precipitous public criticism, and by trying to prevent other subjects of the investigation from hearing prior interviews. View "Hils v. Davis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals vacating the judgments entered upon Defendant's convictions for multiple serious felonies, including first-degree murder, holding that the record did not support the trial court's determination that Defendant's actions were sufficiently obstructive to constitute a forfeiture of his right to counsel.Defendant was indicted on charges of first-degree murder, attempted first-degree murder, and other crimes. The trial court decided before trial that Defendant's actions forfeited his opportunity to have assigned counsel, and Defendant proceeded pro se. The jury returned guilty verdicts on all offenses, and Defendant was sentenced to life imprisonment for the murder conviction. The court of appeals awarded Defendant a new trial, determining that the trial court deprived Defendant of his constitutional right to counsel by concluding that he had forfeited that right. The Supreme Court affirmed, holding that Defendant was entitled to a new trial because he did not engage in the type of egregious misconduct that would permit the trial court to deprive him of his constitutional right to counsel. View "State v. Harvin" on Justia Law

The Supreme Court affirmed the order of the trial court denying the motion for class certification brought by Plaintiffs, inmates in North Carolina Department of Public Safety (DPS) custody, seeking to represent certain individuals in DPS custody who are being or will be subjected to solitary confinement, holding that the trial court did not abuse its discretion.Plaintiffs filed a class action lawsuit seeking to certify a class of current and future inmates assigned to one of five restrictive housing classifications, alleging that the conditions of confinement constituted cruel or unusual punishment. The trial court denied Plaintiffs' motion for class certification, finding that a certifiable class did not exist. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in concluding that Plaintiffs failed to demonstrate a common predominating issue among the proposed class members. View "Dewalt v. Hooks" on Justia Law

The Supreme Court exercised is constitutional power to address constitutional violations through equitable remedies by affirming and reinstating the trial court's directive instructing certain State officials to transfer the funds necessary to comply with years two and three of the State's comprehensive remedial plan (CRP), holding that this Court has an obligation to safeguard the constitutional rights of North Carolina's schoolchildren.In November 2021, the trial court issued the order before the Supreme Court for review. In the order, the trial court declared that the State had failed to fulfill its constitutional obligations to provide school children, especially those at risk and socioeconomically disadvantaged, their constitutional right to a sound basic education. The trial court ordered the State to transfer the total amount of funds necessary to effectuate years two and three of the CRP. The State Controller sought an order preventing her from being required to comply with the trial court's order. The court of appeals issued a writ of prohibition restraining the trial court from proceeding in the matter. Thereafter, the trial court issued an order removing that transfer directive. The Supreme Court stayed the writ of prohibition and reinstated the trial court's November 2021 directive, holding that the judiciary must fulfill its obligation to protect the fundamental rights of the State's individuals. View "Hoke County Bd. of Education v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that the Village of Dorchester was entitled to summary judgment on REO Enterprises, LLC's claims remaining on remand, holding that there was no error.At issue was an ordinance enacted by the Village providing that renters of property could receive utility services from the village only if their landlord guaranteed that the landlord would pay any unpaid utility charges. REO brought this action seeking a declaration that the ordinance was unenforceable. The district court declared that the ordinance violated constitutional equal protection principles, but the Supreme Court reversed and remanded for consideration of REO's other claims. On remand, the district court granted summary judgment in favor of the Village on the remaining claims. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of the Village. View "REO Enterprises, LLC v. Village of Dorchester" on Justia Law

The First Circuit reversed the judgment of the district court denying Appellants' denial of their pre-discovery motions for summary judgment on grounds of qualified immunity, holding that Appellants were entitled to qualified immunity as a matter of law.Appellants - two members of the FBI's joint terrorism task force - shot and killed a suspected terrorist. Plaintiff, the representative of the decedent's estate, brought this action alleging that Appellants' actions violated the decedent's Fourth Amendment rights and asserting state law tort claims. The district court denied Appellants' motions for summary judgment on the grounds of qualified immunity. The First Circuit reversed, holding that the officers were entitled to qualified immunity under each aspect of the "clearly established" prong of the defense. View "Estate of Rahim v. Doe 1" on Justia Law

The First Circuit affirmed the judgment of the district court issuing a preliminary injunction preliminarily enjoining enforcement of a state law before it took effect, holding that the district court properly entered the preliminary injunction.The law at issue was enacted by the Maine legislature in 2021 to prevent Canadian truck drivers from hauling logs within the state under the auspices of the federal H-2A visa program. Just a few days before the law was to take effect Plaintiffs jointly filed suit in federal district court against the Director of the Maine Bureau of Forestry and the Attorney General of Maine (collectively, the State). Plaintiffs sought injunctive and declaratory relief, alleging that the law was preempted under federal law. Plaintiffs then moved for a temporary restraining order and a preliminary injunction against enforcement of the law. The district court granted the motion. The First Circuit affirmed, holding (1) Plaintiffs carried their burden of showing that the H-2A restriction imposed by the law was likely preempted by federal law; and (2) therefore, the district court properly entered the preliminary injunction. View "Maine Forest Products Council v. Cormier" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Calvary Chapel of Bangor's (Calvary) complaint against Maine Governor Janet Mills raising several facial and as-applied constitutional and statutory challenges to the Governor's executive orders seeking to slow the spread of the COVID-19 outbreak in early 2020, holding that the complaint was moot and that no mootness exception could save it.Calvary sued the Governor in federal court claiming that the Governor's orders at issue discriminated against Calvary by treating religious gatherings less favorably than other gatherings. Calvary requested a temporary restraining order, a preliminary injunction, a permanent injunction, and a declaratory judgment. The district court denied relief and dismissed the complaint. The First Circuit affirmed, holding that this case was moot and that no exception to mootness applied. View "Calvary Chapel of Bangor v. Mills" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Employer and dismissing all of Employee's claims alleging retaliatory behavior under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2 et seq., discrimination and retaliation under the Uniformed Services Employment and Reemployment Rights Act, 38 U.S.C. 4301 et seq., and violations of Puerto Rico Law 115, holding that there was no error or abuse of discretion.The district court granted Employer's motion for summary judgment, finding that Employee failed to make a prima facie showing of retaliation and, in the alternative, failed to rebut Employer's explanations for why the behavior in question was non-discriminatory in nature. The First Circuit affirmed, holding (1) there was no abuse of discretion in the district court's conclusion that Employee's statement in opposition to Employer's statement of uncontested material facts was noncompliant with Local Rule 56; (2) the district court properly found that Employee failed to make out a prima facie case for retaliation under Title VII; and (3) the dismissal of Employee's antiretaliation law claims was proper. View "Rodriguez-Severino v. UTC Aerospace Systems" on Justia Law

Plaintiff attended protests in downtown St. Louis. While she was leaving, an armored St. Louis Metropolitan Police Department (“SLMPD”) vehicle fired tear gas in her direction. Plaintiff sued the City of St. Louis, 12 police officers who were members of the SWAT team on duty that night, and several SLMPD officials for constitutional and state law violations. The district court denied a motion to dismiss based on qualified immunity for four Defendant officers specifically alleged to have been in the armored vehicle at the time of the incident. As to eight Defendant officers not specifically alleged to have been in the vehicle, the district court denied the motion to dismiss on the grounds that additional discovery was needed.   The Eighth Circuit reversed the denial of qualified immunity as to the eight Defendant officers for whom specific allegations were not made. The court affirmed as to the four defendant officers for whom specific allegations were made. The court explained that Plaintiff’s allegation, and the district court’s finding, that Plaintiff was not committing a crime when she was tear-gassed is enough to plausibly allege the tear-gassing was in retaliation for the First Amendment activity.  Further, the complaint did not plausibly allege that the eight officers were personally involved in the violation of clearly established constitutional rights. Accordingly, the court reversed the district court’s denial of the Officers’ motion to dismiss. View "Megan Green v. Cliff Sommer" on Justia Law