Justia Civil Rights Opinion Summaries

The Seventh Circuit affirmed the judgment of the district court denying Defendant's motion to suppress without holding an evidentiary hearing, holding that the district court did not abuse its discretion by denying an evidentiary hearing.A law enforcement officer stopped Defendant while he was riding a motorized bicycle and arrested him under the theory that his bicycle was a motor vehicle requiring a license. During the arrest, police searched Defendant and found various drugs and drug paraphernalia. Defendant filed a motion to suppress, arguing that the government needed to establish probable cause that he was driving a motor vehicle on a revoked license. The district court summarily denied the motion. The Seventh Circuit affirmed, holding that the evidence established that the arresting officer had probable cause to believe that Defendant rolled past a stop sign, which independently supported Defendant's arrest. View "United States v. Norville" on Justia Law

The Sixth Circuit affirmed in part, reversed in part and vacated in part the district court's denial of Appellant's petition for a writ of habeas corpus, holding that, in Tennessee, ineffective assistance of post-conviction counsel can establish cause to excuse a defendant's procedural default of a substantive claim of ineffective assistance at the motion-for-a-new-trial stage of the proceedings.Appellant was convicted of first-degree premeditated murder, first-degree felony murder, aggravated kidnapping, rape of a child, and criminal impersonation. The jury sentenced Appellant to death. The Tennessee Supreme Court affirmed. Appellant later filed a habeas petition, which the district court denied. The Sixth Circuit (1) affirmed the district court with respect to the guilt phase of Defendant's trial; (2) held that Appellant's counsel rendered ineffective assistance at the sentencing phase, requiring remand with instructions to grant habeas on this claim as to the penalty phase; and (3) vacated the district court's findings that Appellant failed to overcome his procedural default on certain claims; and (4) reversed the court's finding that the Martinez-Trevino exception to procedural default cannot excuse a procedural default when the underlying ineffective assistance occurred in a motion for a new trial. View "Rogers v. Mays" on Justia Law

Michael Cruz sued defendant insurance companies alleging they terminated his contract, under which he sold defendants’ insurance products, on the basis of race, in violation of 42 U.S.C. § 1981. In support, Cruz relied on a statement allegedly made by his district manager, which Cruz argued represented direct evidence of discrimination, as well as circumstantial evidence. The district court granted summary judgment to defendants, ruling that the district manager’s statement was inadmissible hearsay and that Cruz’s circumstantial evidence did not otherwise demonstrate discriminatory intent. Without considering Cruz’s circumstantial evidence, the Tenth Circuit reversed because the district manager’s alleged comment was not inadmissible hearsay; it was admissible under Federal Rule of Evidence 801(d)(2)(D) as a party-opponent admission made by an agent within the scope of the agency relationship. And because that admission constituted direct evidence of discrimination, the grant of summary judgment was reversed and the matter remanded for further proceedings. View "Cruz v. Farmers Insurance, et al." on Justia Law

In this complaint brought under 42 U.S.C. 1983 and 42 U.S.C. 1985(3) relating to the custody of Plaintiffs' children, the Seventh Circuit affirmed the judgment of the district court dismissing this suit seeking damages for alleged violations of Plaintiffs' constitutional rights to familial integrity, free exercise of religion, and due process of law, holding that there was no error.Plaintiffs brought this action seeking money damages and equitable relief for actions Defendants took with respect to three of their daughters. On appeal, Plaintiffs challenged the dismissal of their claims for money damages regarding the custody of S.M. and D.M. The Seventh Circuit affirmed, holding (1) the judge properly dismissed as untimely all claims relating tot he custody of S.M.; and (2) as to the remaining claims, the trial judge properly concluded that the complaint failed to allege conduct plausibly exposing Defendants to liability and that other claims were foreclosed by absolute immunity. View "Milchtein v. Milwaukee County" on Justia Law

In this action brought the estate of Jonah Marciniak and Marciniak's son pursuing both federal and state claims stemming from Marciniak's arrest and ensuing suicide, the Seventh District held that the district court did not err in granting summary judgment in favor of the Village of Shorewood and three of its officers who arrested Marciniak after his roommate fell from a fourth story window, holding that there was no error.After arresting Marciniak and placing him in a booking cell, Marciniak used his t-shirt to hang himself. Marciniak died six days later. Plaintiffs brought this action alleging that the three officers falsely arrested Marciniak without probable cause and failed to provide medical care and attention and to protect from self-harm. The district court granted summary judgment in favor of Defendants. The Seventh Circuit affirmed, holding (1) Defendants had an absolute defense of probable cause to Plaintiffs' claims; and (2) even if the officers did not have probable cause to arrest for battery, they were still entitled to qualified immunity. View "Jump v. Village of Shorewood" on Justia Law

The Seventh Circuit reversed the order of the district court granting summary judgment and dismissing this complaint brought by Plaintiff after he was fired from his commissary job while incarcerated at Indiana State Prison, holding that the district court erred in finding that Plaintiff failed to comply with the Prison Litigation Reform Act's (PLRA) exhaustion requirement, 42 U.S.C. 1997e(a).Plaintiff was hired for a job in the commissary with the understanding that he would miss work on Fridays to attend the prison's weekly Jumu'ah Muslim prayer service. When Officer Julie Anton refused to allow Plaintiff to attend Jumu'ah and he went anyway, Anton fired Plaintiff based on a work evaluation accusing Plaintiff of theft. Plaintiff sued Anton under 42 U.S.C. 1983, alleging a violation of his First Amendment rights. The district court dismissed the complaint because Plaintiff did not file a formal grievance before bringing suit. The Seventh Circuit reversed, holding that the prison's grievance policy excepted Plaintiff's claim from the prison's administrative process. View "Miles v. Anton" on Justia Law

The Supreme Court affirmed the orders entered by the Fourth and Eighteenth Judicial District Courts denying their requests for preliminary injunctions to enjoin the masking requirements of Defendants, school districts in Missoula and Gallatin Counties, that were adopted in response to the continuing COVID-19 pandemic, holding that the district courts did not err.Plaintiffs filed complaints and motions for preliminary injunctions shortly after Defendants' adoption of the masking policies for the 2021-2022 school year, seeking to enjoin the masking requirements based upon constitutional privacy, individual dignity, and parental rights. Both district courts denied the motions. The Supreme Court affirmed, holding that the district courts did not manifestly abuse their discretion by denying the preliminary injunctions. View "Stand Up Montana v. Missoula County Public Schools" on Justia Law

The First Circuit dismissed this appeal, in which Appellant sought to override an appeal waiver and to proceed with an appeal based on the alleged ineffective assistance of his counsel, holding that ineffective assistance of counsel claims not raised in the district court and not within an exception to United States v. Mala, 7 F.3d 1058 (1st Cir. 1993), are insufficient to overcome an appeal waiver.Defendant agreed to plead guilty to conspiracy to commit bank fraud and to failure to appear in court pursuant to a plea agreement that contained a waiver-of-appeal provision. After sentencing, Defendant appealed, asserting for the first time that his counsel afforded him ineffective assistance both at the time he entered his plea and at sentencing. The First Circuit dismissed the appeal, holding that Defendant's ineffective assistance of counsel allegations fell within the Mala rule and could not surmount his waiver of appeal. View "United States v. Staveley" on Justia Law

The Sixth Circuit affirmed the order of the district court granting summary judgment in favor of the City of Powell, Ohio and dismissing Golf Village North LLC's claims brought under 28 U.S.C. 1983 for violating its procedural and substantive due process rights, holding that there was no error.Golf Village, a developer, sought to build a "residential hotel" on its property in Powell, Ohio but never filed the required zoning application. Instead, Golf Village requested that the City confirm the residential hotel was a permitted use of the property. The City directed Golf Village to file an appropriate application for "zoning Certificate approval" to receive an answer. Rather than reply, Golf Village sued the City. The district court granted summary judgment for the City. The Sixth Circuit affirmed, holding that Golf Village's procedural due process and substantive due process rights were not violated in this case. View "Golf Village North, LLC v. City of Powell, Ohio" on Justia Law

Plaintiff sued the National Geospatial-Intelligence Agency and the Director of the Central Intelligence Agency alleging religious discrimination and retaliation under Title VII. The Fourth Circuit affirmed the district court’s dismissal. The court explained that because the alleged discrimination and retaliation arose from Plaintiff’s failure to satisfy additional security requirements and would require the court to review the merits of the security-authorization decision, the court is bound by the decision in Department of the Navy v. Egan, 484 U.S. 518 (1988), to affirm the district court’s dismissal of this matter for lack of jurisdiction.   The court explained that it agrees that courts must exercise caution in expanding the reach of Egan. Nevertheless, the court declined to adopt the hardline position, urged by Plaintiff, that Egan’s rationale may only ever apply to determinations explicitly labeled “security clearances.” Rather, as in Foote and Sanchez, this case requires a more detailed analysis of whether the judgment at issue is of the type that Egan intended to shield from judicial review. Furhter, the court held that the CIA’s decision to stop Plaintiff’s assignee-security authorization processing is the kind of discretionary predictive judgment shielded from judicial review by Egan. View "Nathan Mowery v. National Geospatial Intelligence Agency" on Justia Law