Justia Civil Rights Opinion Summaries

S.B., age 13, lived with his mother in Michigan and visited relatives in Indiana. S.B.’s uncle, Hinkle, isolated and molested S.B. during two visits. By the time he was 17, S.B. used opiates and marijuana regularly and had experimented with heroin. During a family meeting to address his drug use, S.B. admitted his drug use and that Hinkle had molested him.Hinkle was charged with child molesting, sexual misconduct with a minor, and being a repeat sexual offender. Hinkle’s counsel opposed a motion to exclude evidence of S.B.’s drug use, arguing the evidence was relevant to show S.B.’s motive to fabricate allegations. The court ruled that it would not allow evidence of S.B.’s drug use except to show that it interfered with his ability to recall relevant events. At trial, Hinkle’s counsel unsuccessfully argued (outside the jury’s presence) that S.B. had falsely accused Hinkle to avoid facing consequences when his family confronted him for using narcotics. The jury heard evidence that S.B. “ha[d] a habit of playing family members against each other,” and was “really good at lying.” S.B. testified that he had convictions for credit card fraud, auto theft, and retail fraud.Hinkle was convicted and sentenced to 42 years in prison. The Seventh Circuit affirmed the denial of his habeas petition. The Court of Appeals of Indiana did not unreasonably apply federal constitutional law in upholding the exclusion of evidence of S.B.’s drug use. View "Hinkle v. Neal" on Justia Law

The Supreme Court approved of the decision of the First District Court of Appeal affirming Defendant's conviction for sexual battery in violation of Fla. Stat. 794.011(5)(b), holding that subsection 5(b) is not facially unconstitutional because it does not remove the State's burden to prove the defendant's general intent to engage in the act that constitutes the offense under the statute.On appeal, Defendant argued that subsection 5(b) was facially unconstitutional or must be read to include a requirement that the State prove that a criminal defendant knew or should have known the victim did not consent to sexual intercourse. The First District affirmed, disagreeing with Defendant that section 794.011(5)(b) was unconstitutional because it does not require the State to prove a defendant's mens rea. The Supreme Court affirmed, holding that the Legislature's reach did not approach the extent of its constitutional grasp where the statute makes sexual battery a crime of general intent not a strict liability offense. View "Statler v. State" on Justia Law

The Supreme Court reversed the judgment of the court of appeals determining that the evidence should have been suppressed in the underlying criminal case based on a statutory violation, holding that there was no violation of Defendant's Fourth Amendment rights in this case.While Defendant was serving community control, his probation officer conducted a random home-check on Defendant, searched his cell phone, and discovered child pornography. Defendant moved to suppress the uncovered evidence on the grounds that the suspicion-less search violated the Fourth Amendment. The district court denied the suppression motion. The court of appeals reversed, concluding that the search violated Ohio Rev Code 2951.02(A)'s requirement that a probation officer may conduct a search only when there are "reasonable grounds to believe" that a probationer is violating the law or conditions of control. The Supreme Court reversed, holding (1) the probation officer exceeded the scope of her authority when she searched Defendant's cell phone without reasonable grounds to believe that he had violated the law or the conditions of probation; and (2) because there was no constitutional violation, there was no basis to exclude the evidence obtained as a result of the search. View "State v. Campbell" on Justia Law

Plaintiff fled from three officers investigating drug activity. An officer chased Plaintiff and commanded him to stop. Eventually, Plaintiff stopped and turned suddenly toward the officer. The officer feared Plaintiff was reaching for a weapon, so he tased him. Plaintiff and his grandmother sued Harris County and the officer. The district court dismissed the Monell claim against Harris County for failure to state a claim and granted summary judgment to the officer based on qualified immunity.   The Fifth Circuit affirmed. The court explained that to establish Monell liability on a failure-to-train theory, a plaintiff must prove that: “(1) the city failed to train or supervise the officers involved; (2) there is a causal connection between the alleged failure to supervise or train and the alleged violation of the plaintiff’s rights; and (3) the failure to train or supervise constituted deliberate indifference to the plaintiff’s constitutional rights.”   Here, first, Plaintiff has not plausibly alleged that the County failed to train the officers involved on the constitutional use of tasers. Second, Plaintiff has not plausibly alleged a causal connection between any failure to train officers and the alleged violation here. Third, has not plausibly alleged that any failure to train constituted deliberate indifference. The court further explained that Plaintiff concededly ran from police, then stopped suddenly and turned toward the pursuing officer. Thus, neither Newman nor Darden involves materially similar facts and hence cannot clearly establish the law. View "Henderson v. Harris County" on Justia Law

Appellants distribute food to homeless people in the City of St. Louis and wish to continue doing so as part of their charitable and religious practice a St. Louis police officer observed Appellants distributing bologna sandwiches and issued each a citation for violating a city ordinance requiring a permit for the distribution of “potentially dangerous food.”Appellants filed this suit, claiming that the City’s enforcement of the ordinance violated their federal and state constitutional rights and Missouri statutes. The district court granted the City’s motion for summary judgment and declined to exercise supplemental jurisdiction over the state claims.   The Eighth Circuit affirmed. The court explained that the provisions ensure that health inspectors have an opportunity to determine whether the temporary food establishment is complying with the Ordinance. When operating a temporary food establishment, Appellants would also have to ensure: that they take steps to prevent contamination of any ice served to consumers; that tableware provided to consumers is only in single-service and single-use articles; that any equipment is located and installed in a way that avoids food contamination and to facilitate cleaning; that food-contact surfaces are protected from consumer contamination; and that they have water available for cleaning utensils and equipment and to make convenient handwashing facilities available for any employees. Without these provisions regarding the distribution of potentially hazardous food to the public, the City’s goal of preventing foodborne illness would be achieved less effectively. Moreover, the court noted that nothing about the City’s enforcement of the Ordinance against Appellants prevents them from conveying their religious message in other ways. View "Raymond Redlich v. City of St. Louis" on Justia Law

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