Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of one count of incest, holding that Defendant was not entitled to reversal of his convictions based on any of his allegations of error.Specifically, the Supreme Court held (1) the district court did not err in finding that Defendant had not demonstrated that the victim's allegations against other male relatives were false and thus inadmissible under the Rape Shield statute; (2) Defendant's ineffective assistance of counsel claim was inappropriate for review on direct appeal; and (3) this Court declines to exercise plain error review to consider whether Defendant received a fundamentally fair trial when the district court did not sua sponte exclude testimony of false reporting statistics. View "State v. McCaulou" on Justia Law

Colerain Township prohibited the public from posting “inappropriate” or “offensive” comments on the police department’s Facebook page and prohibited the public from making “disrespectful” comments at its board of trustees meetings. Davis was active in criticizing the board and the department, through oral comments at board meetings and written comments on the Facebook page. Davis sued under 42 U.S.C. 1983 alleging that the Township had violated the First Amendment. She alleged that the prohibitions discriminated against speech based on the speaker’s viewpoint and that the (alleged) removal of her video from the Facebook page amounted to retaliation. The parties agreed that the comments section of the Facebook page and the public-participation portion of board meetings were “limited public forums.” The district court rejected Davis’s challenges to the Facebook Rule, finding the categorical ban on posting videos viewpoint-neutral and reasonable. It upheld the Meeting Rule, finding that the board had not applied it to Davis in a discriminatory way. It rejected overbreadth and vagueness challenges.The Sixth Circuit affirmed, rejecting Davis’s claims for lack of jurisdiction. Davis did not raise her free-speech claims in an Article III case or controversy. She failed to show that the Facebook rule has injured her in the past or is likely to do so in the future. The Township has repealed the meeting rule. View "Davis v. Colerain Township, Ohio" on Justia Law

In August 2009, Kennedy and his father were arrested by Philadelphia police during an armed home invasion. In October 2013, after numerous delays, they went on trial. Both were convicted. Kennedy was sentenced to 10-15 years of imprisonment. After failing to obtain redress under the Pennsylvania Post-Conviction Relief Act, Kennedy’s appeal was rejected by the Pennsylvania Superior Court. In July 2019, Kennedy filed a pro se federal habeas petition, arguing that his right to a speedy trial had been violated. The district court denied Kennedy’s petition on grounds of procedural default and adopted the state-court finding that only 16 days of the 50-month delay in bringing Kennedy to trial were attributable to the Commonwealth. The court additionally held his petition to be “without merit."The Third Circuit reversed, concluding that Kennedy’s procedural default was excused and that his Sixth Amendment Speedy Trial Right was violated. The Commonwealth had, in the interim, conceded that Kennedy’s Sixth Amendment claim was exhausted. The court noted that a 50-month delay is exceptional and that the Commonwealth did not overcome the presumptive prejudice of a four-year delay, despite the strength of its case at trial. Kennedy has also identified prejudice stemming from loss of employment, anxiety, and incarceration. View "Kennedy v. Superintendent Dallas SCI" on Justia Law

Plaintiff brought suit pursuant to the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. Section 2000cc et seq., the Free Exercise Clause of the First Amendment, and Arizona state law. He claimed he is unable to pray five times a day, as the Qur’an requires because he is housed with people who harass him as he prays; and who had asked the prison to accommodate his religious practice by housing him exclusively with other prisoners based on their religious beliefs and practices.   The Ninth Circuit affirmed the district court’s judgment on the pleadings. The panel held that Al Saud’s RLUIPA claim failed because denying his request to be housed only with Muslims was the least restrictive means of furthering a compelling governmental interest. The panel concluded that the outcome of this case was largely controlled by Walker v. Beard, 789 F.3d 1125 (9th Cir. 2015), which held that a prison could deny a prisoner’s religious accommodation when he sought to be housed with only white people.   The panel held that Defendants did not violate Plaintiff's First Amendment free exercise rights because denying Plaintiff’s request was also reasonably related to a legitimate penological interest—avoiding the potential legal liability of housing inmates based on their religious beliefs and practice. Denying the request was rationally related to avoiding liability because by denying Plaintiff’s requested accommodation, the Arizona Department of Corrections Rehabilitation and Reentry completely eliminated its risk of litigation from other prisoners based on that claim. View "SHAYKH MUHAMMAD AL SAUD V. PANNAN DAYS, ET AL" on Justia Law

The Supreme Court affirmed the denial of Appellant's petition for postconviction relief arguing that the district court committed reversible error by denying his pretrial motion to suppress his statements to law enforcement officers, holding that the district court did not abuse its discretion by denying Appellant's request for postconviction relief.Appellant was convicted of second-degree murder and first-degree arson and sentenced to a total of 528 months in prison. Appellant later filed for postconviction relief, asserting that the district court committed reversible error by denying his pretrial motion to suppress statements he made to law enforcement officers. The district court denied relief on the grounds that Appellant was not subjected to custodial interrogation at the time he made his statements. The court of appeals affirmed on different grounds. The Supreme Court affirmed on the grounds cited by the district court, holding that Defendant could not invoke his Fifth Amendment right to counsel because no custodial interrogation took place. View "Charette v. State" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) in this criminal case, holding that because the information omitted the crime of forgery in the second degree's states of mind, it failed to state an offense as to counts 4-7 and violated Defendant's right to due process.Defendant was charged via information with four counts of forgery in the second decree. Defendant filed a pretrial motion to dismiss counts 4-7 charging him with forgery in the second degree because the information omitted forgery's states of mind. In response, the State argued that intent to defraud is an element, understandable to the common person, and gave notice to Defendant of forgery's state of mind. The circuit court granted Defendant's motion to dismiss. The ICA reversed. The Supreme Court reversed, holding (1) Defendant's information did not identify forgery's states of mind, intentionally and knowingly; and (2) therefore, counts 4-7 failed to state an offense and violated Defendant's right to due process. View "State v. Garcia" on Justia Law

The Supreme Court vacated the adjudicatory and dispositional orders of the circuit court in this termination of parental rights case, holding that the circuit court erred when it terminated Father's parental rights because Father did not receive proper notice of the hearing at which he was purportedly adjudicated.The circuit court terminated Father's parental rights for allegedly abandoning his infant son. Father proposed two assignments of error claiming that he was denied an adjudicatory hearing for a determination whether the child had been abuse and/or neglected as alleged. The Supreme Court vacated the circuit court's order, holding (1) Father did not receive proper notice that the hearing at issue was an adjudicatory hearing from him, and without such notice, Father was not provided due process; and (2) without first holding an adjudicatory hearing, the circuit court could not lawfully proceed to disposition and termination of Father's parental rights. View "In re A.G." on Justia Law

Meyers was one of seven men convicted of the 1989 gang-related murders of Williams and Kaufman in Chicago. In 1995, after Meyers’ conviction was affirmed on direct appeal, he filed a pro se petition for post-conviction, arguing that his trial counsel, Nichols, was ineffective for failing to investigate the scene of the shooting and to establish that a witness, Wilson, would not have been able to see the shooters from his second-floor vantage point. Pointing to Wilson’s post-trial recantation, Meyers added that he was wrongfully convicted based on Wilson’s perjured trial testimony and the prosecution’s subornation to commit perjury. Meyers also argued that his trial counsel, Nichols, was ineffective in failing to interview and present the alibi testimony of Parker. The Illinois appellate court rejected his claims.The Seventh Circuit affirmed the denial of his federal habeas corpus petition. The Illinois Appellate Court did not unreasonably apply “Strickland” in rejecting his claim that Nichols was ineffective for failing to interview and present Parker’s alibi testimony. The risk that the defense would have taken by pursuing that alibi, which contradicted statements made by Nichols after his arrest, is obvious. The state court reasonably determined that his conviction was not based on the knowing use of perjured testimony. View "Meyers v. Gomez" on Justia Law

The Haistens sold discounted animal pesticides and drugs online from their South Carolina home. They operated in violation of multiple FDA and EPA regulations. They sold counterfeit DVDs of movies and television shows that they obtained from China. The Haistens ignored cease-and-desist letters from state regulators and animal pesticides companies. Department of Homeland Security agents began making undercover purchases from the Haistens. Customs and Border Protection (CBP) seized shipments of counterfeit DVDs. Agents then searched the Haistens’ home, which revealed unapproved animal pesticides and drugs, counterfeit DVDs, and business records. In the ensuing prosecution, Count 14 charged the Haistens with trafficking counterfeit DVDs that were seized by CBP officers in Cincinnati. Count 15 charged them with trafficking counterfeit DVDs, that were seized at their home. Defense counsel did not request a jury instruction on improper venue or move for acquittal on Counts 14 or 15 for lack of proper venue in the Eastern District of Pennsylvania. The Haistens appealed, challenging an evidentiary ruling and a statement the government made during its summation. The Third Circuit affirmed.The Haistens then sought relief under 28 U.S.C. 2255, arguing that their trial counsel was ineffective for failing to challenge venue on Counts 14 and 15. The Third Circuit remanded the denial of that motion for the district court to conduct an evidentiary hearing on whether their counsel had a strategic reason for not raising a defense based on improper venue. View "United States v. Haisten" on Justia Law

T.C.’s estate and the passengers of T.C.’s car sued an Arlington police officer and the City of Arlington for the use of excessive force during a traffic stop in violation of the Fourth Amendment. The district court dismissed the passengers’ claims, finding that they could not bring claims as bystanders, and granted summary judgment to the police officer and the City after determining that the police officer was entitled to qualified immunity.   The Fifth Circuit affirmed the dismissal of the passengers’ claims and vacated the grant of summary judgment on T.C.’s claims and remanded it to the district court for further proceedings consistent with this opinion. The court reasoned that here, under T.C’s account, he was shot while he was held in a chokehold in a parked car while evading arrest for several confirmed misdemeanors and an unconfirmed felony parole violation. The police officer was on notice that the use of deadly force is objectively reasonable only where an officer has “a reasonable belief that he or the public was in imminent danger . . . . of death or serious bodily harm.” Again, the officer’s alleged belief that T.C. had a gun was not reasonable, nor was his belief that a parked car posed a danger to himself, the passengers, or the other officers standing on the side of the car. Therefore, the district court erred in granting summary judgment to the officer and perforce dismissing the City. However, because there was no unreasonable use of force against the passengers, no constitutional injury occurred. View "Crane v. City of Arlington" on Justia Law