Justia Civil Rights Opinion Summaries

On November 17, 1997, an Ashtabula Police dispatcher advised officers that Jones, who had outstanding felony warrants, had been spotted. Days earlier, Jones had told his cousin that he “was facing a lot of time” and “was going to shoot at the police if they ever tried to arrest him.” Officer Glover found Jones, who pulled a revolver from his pocket and fired several shots at Glover. Jones kicked Glover in the chest, then fled the scene. Officers apprehended Jones and recovered the weapon, which used hollow-point bullets. Officer Glover died the following morning.Jones was convicted of murder. During the penalty phase, Jones’s counsel presented testimony from a clinical psychologist who diagnosed Jones with Antisocial Personality Disorder and testified that Black men with this disorder (including Jones) would commit more murders—he claimed that about one in four “African-American urban males” suffered from the disorder, and the only treatment was to “throw them away, lock them up.” The jury recommended and the court imposed the death penalty. The district court denied Jones’s petition for habeas relief. The Sixth Circuit reversed. The issue of whether Jones received ineffective assistance of counsel during the penalty phase because his attorneys failed to prepare expert witnesses properly, as shown by the psychologist’s racialized testimony, was not procedurally defaulted. On de novo review of the merits, the court held trial counsel performed ineffectively and Jones is entitled to a new sentencing. View "Jones v. Bradshaw" on Justia Law

After the prosecutor used peremptory strikes against three Hispanic women during jury selection, Petitioner raised an objection pursuant to Batson v. Kentucky, 476 U.S. 79 (1986). The trial court denied the challenge, and the California Court of Appeal affirmed on direct appeal. The California Supreme Court summarily denied review.   The Ninth Circuit affirmed the district court’s denial of a California state prisoner’s habeas corpus petition raising a Batson challenge to a jury conviction. The panel held that, even if a combined race and gender class such as Hispanic women is a cognizable group for purposes of Batson, that new rule would not apply to Petitioner’s case. The panel concluded that, under circuit precedent in Cooperwood v. Cambra, 245 F.3d 1042 (9th Cir. 2001), and Turner v. Marshall, 63 F.3d 807 (9th Cir. 1995), the recognition of a mixed race and gender class would be a new rule. Teague v. Lane, 489 U.S. 288 (1989), bars the application of new constitutional rules of criminal procedure to cases that were final before the new rule was announced.   The panel further held that Petitioner did not establish a prima facie case of discrimination based on race alone because the totality of the circumstances, including a comparison between the prospective jurors the prosecutor struck and those he did not, did not raise an inference that race motivated the prosecutor to exercise a strike. Accordingly, the California Court of Appeal’s decision on Batson step one was not contrary to or an unreasonable application of clearly established federal law or an unreasonable determination of facts. View "GIANG NGUYEN V. SCOTT FRAUENHEIM" on Justia Law

The First Circuit affirmed the judgment of the district court awarding plaintiff Elba I. Falto De Roman only nominal damages against the Municipal Government of Mayguez and against its mayor, Jose Guillermo Rodriguez, on her complaint filed after was terminated from her position without having been afforded a due process hearing, holding that there was no error.Plaintiff brought this action alleging, among other things, that Defendants violated her Fourteenth Amendment right to due process by terminating her without a hearing. After a trial on the issue of whether Plaintiff was entitled to damages as a result of not receiving a hearing, the jury found Defendants not liable for damages and awarded nominal damages of $1 in favor of Plaintiff. The district court denied Plaintiff's subsequently-filed motion for judgment as a matter of law or, alternatively, for a new trial. The First Circuit affirmed, holding (1) Plaintiff waived her challenge to the district court's denial of her motion for judgment; and (2) Plaintiff did not meet the high bar for a new trial. View "Falto-de Roman v. Municipal Government of Mayaguez" on Justia Law

Plaintiff was fired from his position as the Chief of Investigation of the Mississippi State Penitentiary at Parchman (Parchman) about three months after he testified at a probable cause hearing on behalf of one of his investigators. Rogers sued the Mississippi Department of Corrections (MDOC), then-MDOC Commissioner, and MDOC’s Corrections Investigations Division Director, under 42 U.S.C. Section 1983, alleging a First Amendment retaliation claim. The district court granted summary judgment for the defendants based on sovereign and qualified immunity. The Fifth Circuit affirmed.   The court explained that to defeat qualified immunity, Plaintiff must show that the defendants violated a right that was not just arguable, but “beyond debate.” And he fails to “point to controlling authority—or a robust consensus of persuasive authority that either answers the question Lane left open regarding sworn testimony given by a public employee within his ordinary job duties, or clearly establishes that Plaintiff’s testimony was outside his ordinary job duties as a law enforcement officer (or was otherwise protected speech). Nor does Plainitff point to record evidence demonstrating that his testimony was undisputedly outside the scope of his ordinary job responsibilities, as was his burden to do. View "Rogers v. Hall" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals upholding the revocation of Defendant's probation, holding that Defendant's confrontation argument under N.C. Gen. Stat. 15A-1345(e) was not preserved.Defendant pleaded guilty to discharging a weapon into occupied property and possession of a firearm by a convicted felon. Later, Defendant's probation was revoked following a determination that he had committed new criminal offenses. On appeal, Defendant argued that the trial court violated his constitutional right to confront witnesses against him at the probation hearing. The court of appeals affirmed, holding that there was no Sixth Amendment violation in this case. The Supreme Court modified and affirmed the judgment below, holding (1) a defendant's arguments under N.C. Gen. Stat. 15A-1345(e) are preserved when a defendant lodges a proper objection or the trial court does not permit confrontation and fails to make a finding of good cause; and (2) the condition requiring a finding of good cause was not satisfied in this case. View "State v. Jones" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the order of the trial court denying Nation Ford Baptist Church Inc.'s (Church) motion to dismiss the underlying complaint with respect to Pastor Phillip R.J. Davis's claim for a declaratory judgment, holding that certain claims must be dismissed for lack of subject matter jurisdiction.Pastor Davis filed a complaint against the Church and Nation Ford's Board of Directors, arguing that the Board exceeded its authority under the Church's corporate bylaws when it purported to terminate him by vote of the Board because the governing bylaws allowed termination only by vote of the Church's congregation at a special general meeting. The trial court denied the Church's motion to dismiss, and the court of appeals affirmed. The Supreme Court reversed in part, holding (1) Pastor Davis's claim for a declaratory judgment regarding the various bylaws can proceed; and (2) First Amendment principles required the dismissal of Pastor Davis's other claims. View "Nation Ford Baptist Church, Inc. v. Davis" on Justia Law

The Supreme Court modified and affirmed the decision of the court of appeals affirming an order of the superior court resentencing Defendant on his first-degree murder conviction to life with the possibility of parole after twenty-five years and running his first-degree kidnapping sentence consecutively with his murder sentence, holding that Defendant failed to show prejudice.Defendant filed a motion for appropriate relief seeking sentencing under Miller v. Alabama, 567 U.S. 460 (2012). The trial court allowed the motion and resentenced Defendant. On appeal, the court of appeals rejected Defendant's claim that he received ineffective assistance of counsel at sentencing. The Supreme Court affirmed as modified, holding (1) the reasoning below is rejected to the extent it incorrectly suggested that the resentencing court lacked authority to run Defendant's first-degree murder sentence concurrently with his robbery with a dangerous weapon sentences; and (2) the court of appeals correctly concluded that Defendant could not demonstrate prejudice. View "State v. Oglesby" on Justia Law

The Comprehensive Merit Personnel Act (CMPA) governs collective bargaining by employees of the District of Columbia government. It allows officers of the Metropolitan Police Department, like other D.C. government employees, to unionize and engage in collective bargaining. They have done so and are represented by the plaintiff in this case, the Fraternal Order of Police, Metropolitan Police Department Labor Committee, D.C. Police Union (FOP). The police union contends that the statute violates equal protection principles, the Bill of Attainder Clause, the Contract Clause, and the Fifth Amendment Due Process Clause.   The DC Circuit rejected all the challenges concluding that the district court correctly concluded that the FOP’s constitutional claims lack merit. The FOP disputes that police accountability motivated the Council. The court explained that the legislature’s actual motive is “entirely irrelevant”; all that matters is whether there are “plausible reasons” to conclude that the statutory classification furthers a legitimate government interest.   The FOP next contends that section 116 violates the Bill of Attainder Clause. However, the court found that the union makes no serious effort to show that the Council acted beyond its discretion. And the court could discern no express or hidden intent to punish. Further, FOP contends that section 116 violates the Contract Clause. The court explained that retrospective laws violate the Contract Clause only if they “substantially” impair existing contract rights. Here, the union could not have reasonably expected to insulate itself from legal changes after the 2017 Agreement had expired by its terms. View "Fraternal Order of Police, Metropolitan Police Department Labor Committee, D.C. Police Union v. DC" on Justia Law

A man grabbed Flowers’s girlfriend in a bar. After a verbal altercation, the bar’s owner asked both men to leave. Flowers protested but left the bar accompanied by a bouncer and Davis, an off-duty police officer employed as a security guard. While Flowers waited in the parking lot for his girlfriend, he and Davis talked. Officer Renfro, another off-duty Springfield police officer employed by the bar, without warning or provocation, grabbed Flowers and slammed him to the pavement face first, knocking out Flowers’ tooth. Renfro then placed Flowers under arrest. Flowers had not verbally or physically threatened the officers and was not showing any indication that he would resist arrest. The only conduct that Renfro claims justified slamming Flowers to the ground was that Flowers questioned the command to leave the bar and turned around to face Davis within one to two feet of him. Flowers disputes that he ever turned to face Davis.Flowers sued the city, Renfro, and Davis under 42 U.S.C. 1983. The district court denied the defendants’ motions for summary judgment, which asserted that the officers did not violate Flowers’ civil rights and were entitled to qualified immunity. The Seventh Circuit dismissed an appeal for lack of jurisdiction because the district court held that there are genuine issues of disputed fact, material to Flowers’ claim against Renfro; the reasonableness of that use of force would inform a decision on qualified immunity. View "Flowers v. Renfro" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion filed under Wyo. R. App. P. 21 for a new trial based on ineffective assistance of counsel, holding that the district court did not err by denying the motion.After a jury trial, Defendant was convicted of aggravated burglary, aggravated assault and battery, and other crimes after repeatedly confronting his estranged wife and her male friend. On appeal, Defendant argued that the trial court erred in denying his motion for a new trial based on ineffective assistance of counsel. Specifically, Defendant alleged that trial counsel failed properly to advise him of his right to plead not guilty by reason of mental illness. The district court denied the motion, concluding that trial counsel's performance was not deficient. The Supreme Court affirmed, holding that Defendant did not meet his burden to show that prejudice resulted from trial counsel's alleged deficient performance. View "Buckingham v. State" on Justia Law