Justia Civil Rights Opinion Summaries

Jarvela drank several rum-and-cokes, then drove his Silverado to a Shell station to buy cigarettes. Afterward, the store clerk called the police to report that “a drunk guy" had just left driving a black Silverado. In a nearby police cruiser, Officer Trevino spotted the Silverado, speeding and drifting over the road’s center line. Trevino activated his lights and pursued the truck. Jarvela led Trevino on an extended chase. After about five minutes, the road turned to gravel and the Silverado struck a tree. Jarvela fled on foot into a darkened wooded area. Trevino called for backup. Deputy Houk and his service dog, Argo, arrived and began searching with Argo leashed. After about five minutes, Argo found clothing. Moments later Jarvela was visible in the weeds, wrestling with Argo, who was clinging to Jarvela’s arm. Jarvela tried to injure Argo. Houk delivered seven blows to Jarvela's back, yelling “Let go of the fucking dog.” Trevino shot his taser at Jarvela, who rolled onto his back. Trevino again deployed his taser.In Jarvela’s excessive force suit, 42 U.S.C. 1983, the Sixth Circuit held that Houk had no constitutional duty to shout out a warning to Jarvela before searching for him with the dog and was entitled to summary judgment. View "Jarvela v. Houk" on Justia Law

After a decade in state prison for gross sexual imposition and kidnapping, Sharp was released on parole with conditions that required him to refrain from unsupervised contact with minors; obtain his parole officer’s approval of any adult who might supervise his contact with minors; and submit to “warrantless search[es]” of his person and property “at any time.” Under Ohio law, a parole officer may search a parolee without a warrant if he has “reasonable grounds” to suspect that the parolee has violated the law or a parole condition. During his parole, a woman told police that, 10 days earlier, Sharp had sexually assaulted her at his house while her children slept nearby and that Sharp had been assisting her children with transportation. Sharp’s parole officer concluded that Sharp had violated his parole. Nearly three weeks after the alleged assault, officers arrested Sharp, transported Sharp to his home, then conducted a warrantless search and found a loaded firearm.Sharp was charged with possessing a firearm as a felon. The Sixth Circuit affirmed the denial of a motion to suppress the gun. Under the special-needs framework, a parolee search is reasonable under the totality of the circumstances if it was supported by reasonable suspicion. Bailey reasonably suspected that he would find evidence of a parole violation at Sharp’s home. A parolee’s search conditions factor into the reasonableness balance. View "United States v. Sharp" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of threats of violence in violation of Minn. Stat. 609.713, subd. 1, holding that Defendant's constitutional right to a speedy trial was not violated in this case.At issue was whether trial delays caused by judicial orders issued in response to the COVID-19 global pandemic weighed against the State in the evaluation of whether Defendant's constitutional right to a speedy trial had been violated. The Supreme Court answered the question in the negative and affirmed Defendant's conviction, holding (1) trial delays caused by statewide orders issued in response to the COVID-19 global pandemic statewide orders do not weigh against the State; and (2) the State brought Defendant to trial quickly enough so as not to violate his constitutional right to a speedy trial. View "State v. Paige" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the order of the district court granting summary judgment in favor of the County of Anoka in this case concerning the proper interpretation of Minn. Stat. 103D.311, which governs the appointment of watershed district managers, holding that several of the district court's conclusions were erroneous.The City of Circle Pines brought this action alleging that the County followed an improper procedure in reappointing Patricia Preiner, a resident of the City of Columbus, to the Rice Creek Watershed District board of managers. The district court granted summary judgment for the County, ruling that section 103D.311 unambiguously allowed the County the discretion to appoint a manager from any city that neglected to submit a list of nominees. The Supreme Court reversed, holding (1) section 103D.311 is ambiguous; (2) the statute requires the aggregate list of city nominees to have three nominees to be valid; and (3) the requirement under the statute that counties appoint managers from city nominees applies unless those nominees cannot fairly represent the various hydrologic areas in the watershed district. View "City of Circle Pines v. County of Anoka" on Justia Law

The Janesville Wisconsin Police Department created a “no‐preference tow list” to simplify its response to traffic accidents in which a vehicle owner expressed no preference as to which tow company towed their car. Smith is Black and owns Flying A.J.’s Towing Company, which operates in the area. Flying A.J.’s was added to the list. Less than two months later, the Police Department removed the company from its tow list, citing the company’s unresponsiveness and complaints related to one particular tow job.Smith and Flying A.J.’s claim that their removal was due to Smith’s race and in retaliation because, in 2010, Smith had successfully sued the town of Beloit after experiencing racial discrimination by the police department. The Seventh Circuit affirmed the dismissal of those claims under 42 U.S.C. 1983 and 1981. Smith had failed to put forth sufficient evidence to allow a jury to determine that Smith’s race or former complaints caused the decision to remove Flying A.J.’s from the tow list. Smith claimed that a tow company owned by a white man had received a lesser penalty but the situations leading to the two complaints are too dissimilar for any reasonable jury to conclude that the factor leading to any perceived disparate treatment was race. View "Smith v. City of Janesville" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for driving under the influence (DUI), fourth offense, and driving during revocation, second offense, holding that there was no merit to Defendant's assigned errors.After a jury trial, Defendant was found guilty of non-aggravated DUI and of driving during revocation and sentenced to a term of imprisonment. The trial court further revoked Defendant's operator's license for a period of fifteen years following his release from incarceration. On appeal, Defendant alleged five instances of error, including the denial of his motion to suppress. The Supreme Court affirmed, holding (1) the district court did not err in finding that Defendant's warrantless blood test was reasonable for purposes of the Fourth Amendment; (2) there was no error in the district court's challenged evidentiary rulings; (3) the evidence supported the convictions; and (4) Defendant's challenges to the sentences imposed were unavailing. View "State v. Miller" on Justia Law

Myers, a Centerville Police Department detective sergeant, Myers reported to then-Lieutenant Brown and then-Police Chief Robertson, that Lieutenant Lavigne possessed and “possibl[y] disseminat[ed]” sexually explicit photos of minors that he obtained while investigating a “sexting" complaint at Centerville High School. Myers continued to pursue that allegation to no avail. Three years later, Myers sought whistleblower protection and met with City Manager Davis to report new allegations against Robertson, and to repeat the allegation against Lavigne, then met with an outside attorney appointed by Davis. After learning of the investigation, Robertson retired. Myers was interviewed but not hired for the vacant chief post, which went to Brown; the hiring panel included Lavigne. Myers was also passed over for two lieutenant positions. He was admitted to the FBI National Academy but Quantico rescinded that offer after its background investigator spoke to Lavigne. Myers was disciplined for writing a “character letter” for another city employee; the letter was critical of the city. He was later terminated for recording a meeting.Myers sued. alleging First Amendment retaliation under 42 U.S.C. 1983. The Sixth Circuit affirmed the denial of a motion claiming qualified immunity. The district court erred by failing to meaningfully analyze the assertions of immunity by Brown and Davis at the pleadings stage, but Myers plausibly alleged First Amendment retaliation, and the defendants are not yet entitled to qualified or statutory immunity. View "Myers v. City of Centerville, Ohio" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, attempted murder, and conspiracy to commit murder and sentencing Defendant to death, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) the trial court properly excluded two prospective jurors for cause; (2) the "substantial impairment" standard used for determining jury bias in capital cases did not violate Defendant's Sixth Amendment right to an impartial jury; (3) there was no constitutional violation in the denial of Defendant's motion to dismiss the charges against him; (4) there was no error in the court's evidentiary rulings; (5) the trial court erred by failing to provide the jury with a cautionary instructions defining confessions, but the error was harmless; (6) Defendant did not demonstrate any basis for the Court to find error in California's death penalty laws; and (7) a limited remand was appropriate for the sole purpose of allowing the trial court to consider whether to exercise its discretion to strike the prior serious felony enhancement and the firearm enhancements. View "People v. Mataele" on Justia Law

Peoples led a gang that robbed four Indiana banks in 1997-1998, brandishing an assault rifle. At least once, he pointed the gun at tellers and threatened to kill them. Peoples stole getaway cars; twice he burned them. A jury convicted Peoples on multiple counts of armed bank robbery (18 U.S.C. 2113(d)), using a firearm during a felony (section 924(c)) and to commit a felony (844(h)), and maliciously destroying a vehicle by fire (844(i)). The four 924(c) convictions required the imposition of consecutive minimum sentences totaling 65 mandatory years. The two 844(h) convictions required a sentence of at least 30 consecutive years. Peoples was sentenced to almost 111 years.In prison, Peoples has successfully completed many classes and received no disciplinary infractions. Peoples, at substantial risk to his own safety, took steps to save another person’s life in prison. Nine correctional officers supported his motion for compassionate release under 18 U.S.C. 3582(c)(1)(A)(i), which cited his rehabilitation and the reality that, under the First Step Act’s amendments to 924(c), he would face a much shorter sentence today for the same armed bank robberies.The Seventh Circuit affirmed the denial of the motion. In a compassionate release motion, the prisoner must identify an ‘extraordinary and compelling’ reason warranting a sentence reduction, but that reason cannot include, alone or in combination with other factors, consideration of the First Step Act. Peoples otherwise failed to identify an extraordinary and compelling reason warranting early release. View "United States v. Peoples" on Justia Law

Plaintiff appealed from the district court’s dismissal of her claim under 42 U.S.C. Section 1983 alleging that a sheriff’s deputy used excessive force in arresting her. The district court held that Plaintiff’s claim was barred by Heck v. Humphrey, 512 U.S. 477 (1994), because Plaintiff was convicted of willfully resisting, delaying, or obstructing the deputy during the same interaction in violation of Cal. Penal Code section 148(a)(1).   The en banc Ninth Circuit court reversed the district court’s summary judgment for Defendants. The court held that because the record did not show that Plaintiff’s section 1983 action necessarily rested on the same event as her criminal conviction, success in the former would not necessarily imply the invalidity of the latter.   Heck would bar Plaintiff from bringing an excessive force claim under section 1983 if that claim were based on force used during the conduct that was the basis for her section 148(a)(1) conviction. Crucially, the criminal jury was told that it could find Plaintiff guilty based on any one of four acts she committed during the course of her interaction with the Deputy. Because the jury returned a general verdict, it is not known which act it thought constituted an offense. Although any of the four acts could be the basis for the guilty verdict, Plaintiff’s section 1983 action was based on an allegation that the Deputy used excessive force during only the last one. The court held that if Plaintiff were to prevail in her civil action, it would not necessarily mean that her conviction was invalid; and the action was therefore not barred by Heck. View "GABBI LEMOS V. COUNTY OF SONOMA" on Justia Law