Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual intercourse without consent, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by excluding evidence related to Defendant's accuser's pending DUI charge in another county; (2) the district court did not violate Defendant's constitutional right to confront the witnesses against him or present his defense by limiting cross-examination of Defendant's accuser regarding alleged leniency she may have received related to her pending DUI case in return for her testimony against Defendant; and (3) the chief prosecutor’s prior representation of Defendant did not deprive the entire Lake County Attorney’s Office of authority to prosecute Defendant. View "State v. James" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that Ohio Rev. Code 4117.11(B)(7) does not violate the First Amendment, holding that the statute's prohibition on inducing or encouraging targeted picketing in connection with a labor-relations dispute violates the First Amendment.Section 4117.11(B)(7) makes it an unfair labor practice for an employee organization or public employees to "induce or encourage any individual in connection with a labor relations dispute to picket the residence or any place of private employment of any public official or representative of the public employer.” The common pleas court in this case rejected a constitutional challenge to the statute, ruling that section 4117.11(B)(7) was a valid, content-neutral time, place and manner limitation on speech. The court of appeals reversed. The Supreme Court affirmed, holding that the law was a form of expressive-activity suppression that was irreconcilable with First Amendment protections. View "Portage County Educators Ass'n for Developmental Disabilities v. State Employment Relations Bd." on Justia Law

This case concerns the denial of qualified immunity to a police officer. Plaintiff and four of her children sued the officer asserting claims for unlawful arrest, bystander injury, and excessive use of force. The district court denied Defendant’s motion for summary judgment on the excessive force claims on qualified immunity grounds. This interlocutory appeal followed.   The Fifth Circuit reversed the district court’s denial of qualified immunity on the excessive force claims and render judgment in Defendant’s favor as to those claims. The court explained that Defendant's conduct, in this case, was not objectively unreasonable and did not violate any of the Plaintiffs’ Fourth Amendment rights. On this basis alone, Defendant is entitled to qualified immunity.   Further, the court wrote, that even assuming Plaintiffs could show that Defendant committed a constitutional violation, Defendant is nonetheless entitled to qualified immunity under the second prong of the qualified immunity analysis. Defendant’s use of force, in this case, is also far less severe than the use of force in any of the cases Plaintiffs have identified. Although Plaintiffs need not point to a factually identical case to demonstrate that the law is clearly established, they nonetheless must provide some controlling precedent that “squarely governs the specific facts at issue. Here, Plaintiffs have not provided such precedent here and thus have failed to show that the law clearly established that Defendant’s particular conduct was unlawful at the time of the incident. View "Craig v. Martin" on Justia Law

The Supreme Judicial Court affirmed the judgment of conviction entered in the trial court upon his conditional guilty plea to drug-related offenses and endangering the welfare of a child, holding that the trial court did not err when it denied Defendant's motion to suppress.Based on evidence discovered during the stop of a Honda Civic the grand jury indicted Defendant on the four counts for which he was later convicted. Defendant moved to suppress the evidence obtained during the stop, arguing that the police officer lacked a clearly articulated and objectively reasonable suspicion to justify the seizure. The trial court denied the motion to suppress, and Defendant entered conditional guilty pleas on all counts. The Supreme Judicial Court affirmed, holding that the vehicle stop was constitutionally permissible, and therefore, the trial court did not err in denying Defendant's motion to suppress. View "State v. Lovell" on Justia Law

Following a government investigation into an afterschool program run by Plaintiff Chabad Chayil, Inc., Defendant Miami-Dade County Public Schools (“MDCPS”) barred Chabad from continuing to use its facilities. Chabad sued both MDCPS and the investigating authority—Miami-Dade County’s Office of Inspector General (“OIG”)—for alleged violations of its federal constitutional rights. The district court dismissed those claims with prejudice and without leave to amend, and Chabad appealed.   The Eleventh Circuit affirmed concluding that the district court properly dismissed all of Chabad’s Section 1983 claims against the MDCPS and OIG, and the court affirmed the dismissal of those claims without leave to amend.   The court explained that the unspecified acts of unidentified OIG investigators in this single case do not plausibly allege an official policy of the OIG, or even a custom that rises to the force of law. Thus, the district court properly dismissed the Free Exercise claim against the OIG. Further, Chabad did not demonstrate that its comparators were similarly situated in all relevant respects. Accordingly, the district court correctly dismissed the Equal Protection claim against the OIG. Moreover, the court explained that to impose liability under Section 1983, the government entity’s actions must be the “moving force” behind the deprivation of a constitutional right. The OIG does not have the authority to refuse any group permission to use school board property–that power lies with MDCPS. Thus, even if the OIG did act in accordance with some official policy or custom, that policy or custom did not cause Chabad’s harm. View "Chabad Chayil, Inc. v. The School Board of Miami-Dade County Florida, et al." on Justia Law

Coby Lee Paugh died from complications related to alcohol withdrawal while being held in pretrial detention at Uintah County Jail in Vernal, Utah. His estate sued Uintah County and several of its jail officials under 42 U.S.C. § 1983, alleging violations of Paugh’s constitutional rights. The County and its jail officials moved for summary judgment, with the jail officials asserting qualified immunity. The district court granted qualified immunity for one but not all defendants. It also denied the County’s motion for summary judgment. The Individual Defendants and the County filed an interlocutory appeal, challenging the district court’s denial of qualified immunity, and the County asked the Tenth Circuit to exercise pendent appellate jurisdiction and reverse the court’s denial of its motion for summary judgment. We hold that the Individual Defendants are not entitled to qualified immunity. After review, the Tenth Circuit affirmed the district court’s denial of the Individual Defendants’ motion for summary judgment, and did not consider the County’s appeal, because it lacked jurisdiction to do so. View "Paugh, et al. v. Uintah County, et al." on Justia Law

At a barbecue at Brown's home. K.M. and Brown became inebriated and had a physical altercation. K.M.’s wife, Rebecca, got K.M. to his car, in front of Brown’s house. According to Rebecca, K.M. was standing in the street when Brown approached and swung a knife at K.M.. K.M. swung back with a piece of wood that Brown had thrown at K.M. earlier. Brown claims K.M. came up the driveway toward him holding pieces of wood and raised his hands as if to strike Brown, so Brown picked up a knife from the grill and swung it. He did not realize he had stabbed K.M. until K.M. collapsed in the street. Brown did not call 911 but made statements such as “that will teach him.” In recorded telephone calls from the jail, Brown made statements attributing the stabbing to anger rather than fear. K.M.’was struck three times; the knife’s blade penetrated his skull and passed through the brain. K.M. survived but has cognitive and physical impairments and will require care for the remainder of his life.Brown was convicted of first-degree reckless injury. The Seventh Circuit affirmed the denial of Brown’s habeas petition. Even if he was deprived of due process when the trial court refused to instruct the jury on the “castle doctrine” as part of his self-defense theory, any error was harmless. It is unlikely that a properly instructed jury would have accepted Brown’s factual account. View "Brown v. Eplett" on Justia Law

Barney’s wife got a restraining order against him and temporary custody of their son. She was subsequently found dead near their son’s daycare, her throat cut open. Barney was charged with murder. Barney had a rocky relationship with his defense lawyer, Riley, and claims that he told Riley of his plan to represent himself on July 14, 2005, then wrote the judge a letter. Though Barney had dated the letter July 21, the judge did not get it until August 10, the day before the trial began. In court, the judge held up the letter, explained that he had not read it, and handed it to Riley. Riley promised Barney that he would “deal with” Barney’s request. He never did.After a two-week trial, Barney was convicted of first-degree murder. His conviction was affirmed. In habeas proceedings, the New Jersey Superior Court found that Barney did not “clearly and unequivocally” tell the court or Riley that he wanted to represent himself. The Third Circuit affirmed the denial of federal habeas relief. The state court ruling was not “contrary to, or involved an unreasonable application of, clearly established” Supreme Court precedent, 28 U.S.C. 2254(d). Barney did not establish prejudice in his ineffective assistance claim; the trial court did not get Barney’s request until the eve of jury selection. View "Barney v. Administrator New Jersey State Prisons" on Justia Law

The Supreme Court reversed Defendant's conviction of murder and criminal possession of a firearm in connection with the death of his wife, holding that the prosecutor improperly commented on Defendant's invocation of his right to remain silent following his arrest and advisement of rights pursuant to Miranda v. Arizona, 384 U.S. 436, 384 U.S. 436 (1966).On appeal, Defendant argued that the evidence was insufficient to establish his identity as the perpetrator of the crimes of conviction and that the prosecutor improperly commented on his post-Miranda silence. The Supreme Court reversed his convictions, holding (1) the evidence was sufficient to support the conviction; but (2) the prosecutor's remarks impermissibly used Defendant's post-Miranda silence against him, in violation of Doyle v. Ohio, 426 U.S. 610 (1976), rendering the trial "fundamentally unfair," and the error was not harmless. View "State v. Patrick M." on Justia Law

Texas City’s “permit officer” handles applications for ambulance permits for the City. One day, he spotted an ambulance without a permit. He knew he was powerless to issue citations to the drivers himself, so he summoned someone who could (the Fire Marshal). While waiting for the Fire Marshal to show up, the officer repeatedly told the ambulance drivers that they were detained, that they could not leave, and that they must stay. He did not have that power, but he did it anyway. The Fire Marshal showed up about thirty minutes later and issued them citations. The ambulance drivers sued, claiming this violated their Fourth Amendment rights.   The Fifth Circuit affirmed in part finding that because the officer acted beyond the scope of his discretionary duties as “permit officer,” he is not entitled to qualified immunity. But the claim against the City fails because the officer did not have final policymaking authority. The court explained that the officer was not acting within the scope of his discretionary authority because state law does not give a permit officer the authority to conduct stops of any kind.   However, the court wrote, that the City cannot be held liable under 42 U.S.C. Section 1983 because Wylie does not have any final policymaking authority. Section 1983 allows suits against persons for violating federal rights. That term includes municipalities like Texas City. But a city cannot be held liable under Section 1983 on a respondeat superior theory of liability. Rather, a city can be liable only if one of its policies or customs caused the injury. View "Sweetin v. City of Texas City" on Justia Law