Justia Civil Rights Opinion Summaries

Antonio Webb, a former state inmate in Missouri, filed a lawsuit against several prison officials, alleging violations of his Eighth Amendment rights. Webb claimed he was subjected to sexual harassment and abuse, that officials failed to protect him from this abuse, and that he faced retaliation for reporting the misconduct. The district court granted summary judgment in favor of the officials, leading to Webb's appeal.The United States District Court for the Western District of Missouri initially handled the case. The officials asserted qualified immunity as a defense in their answer to Webb's complaint but did not file a motion to address it. The case moved forward through discovery, and at a pretrial conference, the officials indicated they had not moved for summary judgment on qualified immunity due to a lack of grounds. However, four days before the trial, the court ordered the officials to file a motion discussing qualified immunity, extended the deadline for dispositive motions, and continued the trial. The officials complied, and the court granted summary judgment, concluding Webb failed to present sufficient evidence of any constitutional violation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court's decision to address qualified immunity before trial was a reasonable exercise of case management, aimed at conserving judicial resources and ensuring fairness. Webb had adequate notice and an opportunity to respond to the motion. On the retaliation claim, the court determined Webb did not provide competent evidence to support his allegations. His declaration was inadmissible as it was not signed under penalty of perjury, and his grievance records did not meet the requirements of Federal Rule of Civil Procedure 56. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Webb v. Lakey" on Justia Law

In May 2020, following the death of George Floyd, several individuals participated in or were near protests in downtown Houston. They allege that they were falsely arrested by City of Houston police officers who used "kettle maneuvers" to confine and arrest protesters. The plaintiffs claim that then-Chief of Police Art Acevedo implemented a policy of "kettling" and arresting protesters. They sued the City and Acevedo under 42 U.S.C. § 1983, alleging violations of the First, Fourth, Fifth, and Fourteenth Amendments, based on the assertion that there was no probable cause for their arrests under section 42.03 of the Texas Penal Code, which prohibits obstructing passageways.The United States District Court for the Southern District of Texas found that there was probable cause to arrest the plaintiffs under section 42.03 and dismissed the claims against both the City and Acevedo. The plaintiffs appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court noted that two previous panels had addressed similar issues with conflicting outcomes. In Utley v. City of Houston, the panel found probable cause for arrest and affirmed the dismissal of the plaintiff’s § 1983 lawsuit. Conversely, in Herrera v. Acevedo, the panel found that the plaintiffs had plausibly alleged false arrest and denied the defendants' motion to dismiss. The current panel agreed with the Utley decision, holding that there was probable cause to arrest the plaintiffs for obstructing a passageway under section 42.03. The court found that the size and location of the protests provided sufficient probable cause for the arrests, thus negating any First, Fourth, or Fourteenth Amendment violations. Consequently, the claims against the City and Acevedo were dismissed due to the lack of an underlying constitutional violation. The judgment of the district court was affirmed. View "Wade v. City of Houston" on Justia Law

Law enforcement responded to the defendant's home after his ex-girlfriend reported that he had threatened suicide during a phone call. The officers, aware of his history of alcohol abuse and mental health issues, entered his home without a warrant after he failed to respond to their attempts to contact him. Inside, an officer shot the defendant, believing he was armed. The defendant was charged with Assault on a Peace Officer.The District Court of the Third Judicial District denied the defendant's pretrial motions to dismiss and suppress evidence obtained from the warrantless entry. The court also denied his motion for a new trial based on an alleged Brady violation, where the defendant claimed the State failed to disclose that the officer who shot him had been shot at in a prior incident. The jury found the defendant guilty.The Supreme Court of Montana reviewed the case and affirmed the lower court's decisions. The court held that the officers' warrantless entry was justified under the community caretaker doctrine, given the exigent circumstances of a potential suicide. The court also found no Brady violation, as the undisclosed evidence about the officer's prior incident would not have changed the trial's outcome. The court concluded that the officers acted reasonably in their entry and subsequent actions, and the defendant's conviction was upheld. View "State v. Case" on Justia Law

The plaintiff, Word Seed Church, now known as Grace Fellowship Covenant Church, sought to establish a permanent location in the Village of Hazel Crest but faced difficulties due to the village's zoning ordinance. The church claimed that the ordinance discriminated against religious assemblies by not listing churches as a permitted use in any zoning district and requiring a special use permit for churches in certain residential districts. The church argued that this process was burdensome and discriminatory, violating the Equal Protection Clause and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the Northern District of Illinois initially denied the church's motion for a preliminary injunction, finding that the church had standing but was unlikely to succeed on the merits. Later, the district court granted summary judgment in favor of the village, concluding that the church did not have a property interest in Hazel Crest and had not shown that comparable secular organizations were treated more favorably. The court also rejected the church's vagueness challenge to the zoning ordinance. The church did not appeal the summary judgment but instead filed a Rule 60(b) motion for relief from judgment, arguing that the district court had evaluated the wrong version of the zoning ordinance. The district court denied this motion.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's denial of the Rule 60(b) motion. The appellate court found that the district court did not abuse its discretion in its decision. The court noted that the church's argument regarding the zoning ordinance amendments was not raised during the summary judgment proceedings and that the church had waived any challenge to the B-2 district, which was affected by the 2008 amendment. The appellate court concluded that the church's difficulties in finding a property were due to the lack of suitable parcels, not the zoning ordinance. View "Word Seed Church v. Village of Hazel Crest" on Justia Law

Christopher Redding was wanted for parole violations related to robbery charges and was classified as a "Violent Felony Offender of Special Concern." On February 28, 2017, police officers, including Deputy Jason Popovich, attempted to arrest Redding at an apartment complex. Redding did not comply with the officers' commands and instead started shooting, injuring one officer. He fled, dropping his gun during the chase. Eventually, Redding was shot multiple times and fell to the ground. As officers, including Popovich, approached him, Redding made a sudden movement, prompting Popovich to shoot him twice in the head, resulting in Redding's death.The United States District Court for the Middle District of Florida granted summary judgment in favor of Popovich on qualified immunity grounds. The court found that while there was a genuine issue of fact regarding whether Popovich's use of force was objectively reasonable under the Fourth Amendment, Franklin, representing Redding's estate, failed to show that Popovich violated clearly established law. The court concluded that a reasonable officer could believe Redding's sudden movement was an attempt to fight back, distinguishing the case from precedents cited by Franklin.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that there was no genuine dispute of fact that Popovich did not know Redding was unarmed. Given the severity of Redding's crimes, his recent shootout with police, and his sudden movement, a reasonable officer could have believed Redding posed a threat. Therefore, Popovich's use of deadly force did not violate the Fourth Amendment, and Franklin failed to show that Popovich's actions violated clearly established law. Consequently, Popovich was entitled to qualified immunity. View "Franklin v. Popovich" on Justia Law

The Human Rights Defense Center (HRDC) sued Union County, Arkansas, and various officials under 42 U.S.C. § 1983, alleging violations of the First and Fourteenth Amendments. HRDC claimed that the defendants refused to accept publications mailed to detainees, which infringed on their rights. The Union County Detention Center had a policy limiting incoming mail to postcards only, aimed at reducing contraband and conserving staff resources. This policy did not apply to inmates in a work-release program. HRDC's mailings were often returned or not returned at all, prompting the lawsuit.The United States District Court for the Western District of Arkansas oversaw the initial trial. HRDC presented testimony from its executive director, the sheriff, the jail administrator, and an expert on jail administration. The district court granted judgment as a matter of law for the defendants on one claim, and the jury found in favor of the defendants on the remaining claims. HRDC's post-trial motions for judgment as a matter of law were denied, leading to this appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that even if publishers have a First Amendment interest in sending unsolicited communications to prisoners, HRDC did not demonstrate a constitutional violation. The postcard-only policy was deemed rationally related to legitimate penological objectives, such as reducing contraband and promoting institutional efficiency. The court also found that HRDC had alternative means of communication through electronic materials available on kiosks and tablets. Additionally, the court concluded that HRDC was not entitled to additional due process for rejected mailings, as the organization was aware of the postcard-only policy. The district court's judgment was affirmed. View "Human Rights Defense Center v. Union County, Arkansas" on Justia Law

Arthur Lee Burton was convicted of capital murder and sentenced to death in June 1998 for kidnapping, sexually assaulting, and strangling a woman in Houston, Texas. His conviction was affirmed by the Texas Court of Criminal Appeals, but his sentence was vacated and remanded for a new trial on punishment. Upon retrial, he was again sentenced to death, and this sentence was affirmed. Burton pursued state and federal habeas relief, which were all denied.Burton recently filed three challenges to his scheduled execution in Texas state court, including motions to withdraw his execution order and a habeas petition alleging constitutional violations. These challenges were rejected by the Texas Court of Criminal Appeals. Subsequently, Burton sought authorization from the United States Court of Appeals for the Fifth Circuit to file a successive federal habeas petition under 28 U.S.C. § 2244(b) and moved to stay his execution.The United States Court of Appeals for the Fifth Circuit denied both motions. The court held that Burton's petition was untimely, as it was filed well beyond the one-year limitation period prescribed by § 2244(d). Burton's reliance on Atkins v. Virginia and Moore v. Texas was insufficient to excuse the delay, as both cases were decided long before his current motion. The court also rejected Burton's arguments for equitable tolling and actual innocence, finding that he had not pursued his rights diligently and that his claims were not supported by extraordinary circumstances. Consequently, the court concluded that Burton failed to meet the requirements of § 2244 and denied his motion to stay execution. View "In re Burton" on Justia Law

A twelve-year-old boy named Maxwell was abused and killed by his father and stepmother. His mother, Sara Coon, sued Lebanon County and several county officials, alleging that the county knew about the abuse and had a state-law duty to protect Maxwell. The complaint stated that the county's Children and Youth Services agency failed to act despite multiple warnings about the abuse.The United States District Court for the Middle District of Pennsylvania dismissed the federal claims brought under 42 U.S.C. § 1983, concluding that Pennsylvania’s Child Protective Services Law did not create a property interest in having the county agency protect Maxwell from child abuse. The court also remanded the state-law claims to state court.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that due process protects interests in life, liberty, or property, and to state a claim for violating procedural due process, a plaintiff must show a legitimate claim of entitlement to a protected property interest. The court found that Pennsylvania law did not create such a property interest in having a county agency protect a child from abuse. The court compared this case to Town of Castle Rock v. Gonzales and Burella v. City of Philadelphia, where similar statutory language did not create a property interest. Consequently, the Third Circuit affirmed the District Court’s order dismissing the federal claims and remanding the state claims to state court. View "Coon v. County of Lebanon" on Justia Law

Carl Langston was convicted of possessing a firearm in violation of 18 U.S.C. § 922(g)(1), the felon-in-possession statute. Langston argued that this statute is unconstitutional under the Second Amendment as applied to him, given his prior convictions for theft and drug trafficking under Maine law. He also challenged the district court's denial of his motion to suppress evidence obtained during a police stop and several sentencing decisions.The United States District Court for the District of Maine denied Langston's motion to suppress, finding that the police stop was based on reasonable suspicion. Langston then entered a conditional guilty plea, reserving the right to appeal the suppression ruling. At sentencing, the district court applied a four-level enhancement for possessing a firearm during a felony assault on an officer and denied Langston a reduction for acceptance of responsibility, citing his conduct during pretrial release.The United States Court of Appeals for the First Circuit reviewed Langston's claims. The court held that Langston's Second Amendment challenge failed under the plain-error standard because it was not "clear" or "obvious" that § 922(g)(1) is unconstitutional as applied to him. The court noted that the Supreme Court has consistently referred to felon-in-possession laws as "presumptively lawful."The court also upheld the district court's denial of the motion to suppress, agreeing that the totality of the circumstances gave rise to reasonable suspicion for the police stop. Additionally, the court found no plain error in the application of the sentencing enhancement for felony assault on an officer and ruled that the district court did not abuse its discretion in relying on hearsay evidence to conclude that Langston violated his pretrial release conditions. Finally, the court affirmed the denial of the acceptance-of-responsibility credit, noting the similarities between Langston's conduct at the time of his arrest and during his pretrial release.The First Circuit affirmed Langston's conviction and sentence. View "US v. Langston" on Justia Law

Bilal Hankins, a passenger in a car with two other youths, was driving slowly at night looking for a neighbor’s lost dog. Hankins asked Officer Kevin Wheeler, who was on patrol for a local private security district, for assistance in finding the dog. Later, Officer Wheeler and another officer, Officer Ramon Pierre, stopped the car without reasonable suspicion and approached it with guns drawn. Hankins brought claims under Sections 1983 for unreasonable seizure, excessive force, constitutional conspiracy, supervisory liability, and Monell claims, along with related state-law claims.The United States District Court for the Eastern District of Louisiana limited discovery to the issue of qualified immunity. The district court concluded that there was no question of material fact as to whether there was an underlying constitutional violation of either Hankins’ right to be free from an unlawful seizure or his right to be free from excessive, unlawful force. Consequently, the district court granted summary judgment to the defendants on all federal claims, as each federal claim relied on an underlying constitutional violation. The court also declined supplemental jurisdiction over the state-law claims and dismissed those without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that material fact disputes precluded summary judgment on the seizure claim. The court held that the factors relied upon by the district court, such as the car’s registration information, the time of night, and the car driving slowly, did not amount to reasonable suspicion when considered in the totality of the circumstances. The court also noted that Hankins’ testimony that Officer Wheeler said, “you know, three young men, in a nice car, in this neighborhood,” if credited, would undermine the officers’ justification for the stop. The Fifth Circuit reversed the summary judgment on the seizure claim, vacated the summary judgment on the other federal claims, and remanded for further proceedings. View "Hankins v. Wheeler" on Justia Law