Justia Civil Rights Opinion Summaries

Defendants appealed from an order denying their motion to dismiss in part and rejecting their qualified immunity defense against the Religious Freedom Restoration Act ("RFRA") claims of Plaintiffs. Plaintiffs are practicing Muslims whose religion requires them to perform daily congregational prayers with as many other Muslims as are available. According to the allegations in their complaint, while Plaintiffs were incarcerated at the Federal Correctional Institution in Danbury, Connecticut, Defendants enforced a policy that restricted group prayer to the prison's chapel, despite that facility's frequent unavailability. As a result, Plaintiffs were forced to forgo their religious exercise of group prayer to avoid disciplinary action.   The Second Circuit affirmed the district court’s order. The court concluded that the wardens are not entitled to qualified immunity at this stage of the proceedings because the pleadings do not establish that their enforcement of the policy against Plaintiffs was in service of a compelling interest, and it was clearly established at the time of the violation that substantially burdening an inmate's religious exercise without justification violates RFRA. View "Sabir v. Williams" on Justia Law

Lamb was involved in an altercation with a WCI correctional office. Lamb alleges that other correctional officers retaliated by beating him and deploying pepper spray against him while he was handcuffed outside the presence of surveillance cameras. That night, Lamb was transferred to the Lebanon Correctional Institution (LeCI), where he was placed in restrictive housing. Lamb filed an internal informal complaint. WCI responded with a computer entry on the prison’s internal system, stating “[y]ou will be able to give your statement during the use of force investigation.” Lamb asserts that he did not receive this response for two years because he did not have access to the System while in restrictive housing. Lamb also alleges that he filed second and third informal complaints and unsuccessfully asked LeCl officers for forms to escalate his grievance. Lamb was transferred to the Southern Ohio Correctional Facility. Lamb allegedly sent an appeal letter to the Chief Inspector of the Ohio Department of Rehabilitation and Correction. There is no record of this letter.Lamb filed a 42 U.S.C. 1983 action. The district court dismissed for failure to exhaust administrative remedies as required by the Prison Litigation Reform Act, 42 U.S.C. 1997e(a). The Sixth Circuit reversed. While Lamb did not exhaust his administrative remedies properly, there remain material disputes of fact about whether prison officials rendered those administrative remedies unavailable. View "Lamb v. Kendrick" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts each of sexual assault in the first degree and unlawful restraint in the first degree and one count of assault in the second degree, holding that Defendant's claims on appeal failed.On appeal, Defendant argued, among other things, that the trial court violated his rights under the Confrontation Clause of the Sixth Amendment to the United States Constitution. The Supreme Court affirmed, holding (1) the trial court violated Defendant's Sixth Amendment rights under State v. Walker, 212 A.3d 1244 (Conn. 2019), by admitting certain testimony, but the violation was harmless under State v. Golding, 567 A.2d 832 (Conn. 1989); (2) Defendant failed to prove a violation of his constitutional right to due process; and (3) the trial court did not abuse its discretion in denying either Defendant's supplemental motion for a new trial or his motion for a new trial. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of deliberate homicide and tampering with or fabricating physical evidence, holding that Defendant's assignments of error were without merit.On appeal, Defendant argued, among other things, that the State's 391-day delay in bringing his case to trial violated his constitutional right to a speedy trial under both the state and federal constitutions. The Supreme Court affirmed, holding (1) where the delay was primarily institutional under the conditions presented at the time by the unprecedented COVID-19 pandemic and where Defendant failed to demonstrate prejudice, Defendant failed to establish that he was denied his right to a speedy trial; and (2) the district court did not err when it denied Defendant's motion to strike the jury panel. View "State v. Hesse" on Justia Law

Roldan was convicted of criminal sexual assault. Roldan, then 21, allegedly had sex with an intoxicated 16-year-old noncitizen. The Illinois Appellate Court later reversed the conviction, concluding that the state did not prove that Roldan knew the victim was too intoxicated to consent.Drawing upon information he learned after trial, Roldan sued Cicero, Illinois police officers under 42 U.S.C. 1983, alleging that the officers failed to disclose an agreement to help the victim apply for an immigration benefit—a U visa—in exchange for her testimony. The officers moved to dismiss the complaint based on qualified immunity. The district court denied the motion on grounds that the Supreme Court’s 1972 “Giglio” decision and related cases clearly established the officers’ duty to disclose the agreement. The Seventh Circuit affirmed that immunity is inappropriate at this early stage but for a different reason. Qualified immunity hinges on a fact that Roldan did not flesh out in his complaint: whether the police officers informed the prosecution about the U-visa agreement with the victim. If the police did, they cannot be liable, for the ultimate disclosure obligation would have rested with the prosecutors. View "Roldan v. Stroud" on Justia Law

Shaw’s pro se complaint alleged that three times in 2018 he needed to use the handicapped bathroom but was unable to because nondisabled prisoners occupied it. Shaw is confined to a wheelchair and incontinent. Each instance ended with Shaw defecating on himself. Shaw alerted prison staff, who asserted that they could not control what toilets other inmates used or reserve the handicapped stall solely for his use. Shaw’s complaint alleged violations of the Americans with Disabilities Act (ADA), the Rehabilitation Act, and constitutional rights.Before allowing the defendants to be served and fulfilling the screening obligation imposed by 28 U.S.C. 1915A(a), the district court addressed the ADA and Rehabilitation Act claims and concluded that Shaw, while unquestionably a qualified person with a disability, failed to allege a denial of access to any prison service and instead complained only about an “inconvenience” of prison life. The Seventh Circuit reversed. Shaw’s allegations suffice to state claims under the ADA and Rehabilitation Act; he will still need to prove his claim and show deliberate indifference. View "Shaw v. Kemper" on Justia Law

This appeal presented only a discrete and important threshold question to the underlying case: whether the Georgia Constitution required a plaintiff to establish some cognizable injury to bring a lawsuit in Georgia courts, i.e., to have standing to sue, separate and apart from the statutory authorization to bring suit. The Georgia Supreme Court found T. Davis Humphries, as a private citizen, had standing to assert a claim for injunctive relief against her local county government for its planned removal of a Confederate monument in alleged violation of OCGA § 50-3-1. But the other plaintiffs — the various Sons of Confederate Veterans entities — did not show that they were members of the communities the governments of which they sought to sue, and they alleged no other cognizable injury sufficient to establish their standing. The Court of Appeals was therefore wrong to affirm the dismissal of Humphries’s complaint for a lack of standing as to her claim for injunctive relief, but it was right to affirm the dismissal of the complaints filed by the various Sons of Confederate Veterans groups. The Supreme Court did not reach the question of whether Humphries had standing for her claim for damages under OCGA § 50-3-1, because the cause of action that statute purported to create had not yet arisen; by the statute’s terms, the cause of action arose only upon the occurrence of conduct prohibited by the statute, and that conduct had not yet occurred. View "Sons of Confederate Veterans, et al. v. Henry Cty. Bd of Commissioners" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the decision of the post-conviction court determining that Appellant's trial counsel provided ineffective assistance by failing to object to certain incomplete or missing jury instructions, holding that defense counsel's failure to object to a "CSI effect" voir dire question did not render her performance constitutionally deficient.In 2007, Appellant was convicted by a jury of murder. In 2010 and 2011, the Court of Appeals held in three cases that a CSI effect message from the bench constituted reversible error. In 2014, Appellant filed a pro se petition for post-conviction relief arguing that he received ineffective assistance of counsel based on his counsel's failure to object to the trial court's CSI effect voir dire question. In 2020, the post-conviction court granted the petition for post-conviction relief and ordered a new trial. The court of special appeals reversed. The Court of Appeals affirmed, holding that under the professional norms that existed at the time of Appellant's trial, defense counsel's failure to object to a CSI-effect voir dire question did not render her performance constitutionally deficient. View "McGhee v. State" on Justia Law

In 2020 Alaska voters approved, by a slim margin, a ballot initiative that made sweeping changes to Alaska’s system of elections. The changes included replacing the system of political party primary elections with a nonpartisan primary election and adopting ranked-choice voting for the general election. A coalition of politically active voters and a political party filed suit, arguing that these changes violated the Alaska Constitution. The superior court ruled otherwise. The Alaska Supreme Court considered the appeal on an expedited basis and affirmed the superior court’s judgment in a brief order. The Court concluded the challengers did not carry their burden to show that the Alaska Constitution prohibited the election system Alaska voters have chosen. The Court published its opinion to explain its reasoning. View "Kohlhaas, et al. v.Alaska, Division of Elections, et al." on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for habeas corpus, holding that the circuit court did not err in denying the petition after holding an evidentiary hearing.Appellant was convicted of three counts of first-degree rape and one count of sexual contact with a child under sixteen for raping and having sexual contact with his four-year-old autistic daughter. The conviction was affirmed on appeal. Appellant later filed a petition for habeas corpus alleging several instances of ineffective assistance of counsel. After a hearing, the circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to establish that his trial counsel provided ineffective assistance. View "Spaniol v. Young" on Justia Law