Justia Civil Rights Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of a panel of the court of appeals affirming Defendant's conviction of possession of more than 3.5 grams of methamphetamine with intent to distribute, possession of a firearm within ten years of a prior felony conviction, and two counts of drug paraphernalia possession, holding that insufficient evidence supported Defendant's firearm possession conviction.On appeal, Defendant raised six allegations of error. The Supreme Court reversed in part, holding (1) the panel erred when it refused to consider for the first time on appeal the legal appropriateness of an intent-to-distribute instruction and the instruction's permissive inference was legally inappropriate, but this error was not prejudicial; (2) Defendant's constitutional challenges failed; (3) there was insufficient evidence to support Defendant's firearm conviction; and (4) Defendant was not entitled to relief on his remaining claims of error. View "State v. Valdez" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the decision of the circuit court convicting Defendant on the charge of first-degree intentional homicide with use of a dangerous weapon and being a felon in possession of a firearm, holding that Defendant's Sixth Amendment right to counsel was not violated.At issue was whether Defendant's constitutional right to counsel was violated when a jail inmate secretly recorded conversations with Defendant and when the State admitted those recordings into evidence. The court of appeals reversed on grounds of ineffective assistance of counsel, concluding that trial counsel's failure to seek suppression of the recording fell below an objective standard of reasonableness. The Supreme Court reversed, holding that Defendant's Sixth Amendment right to counsel was not violated because Defendant was not acting as a State agent when he recorded his conversations with Defendant. View "State v. Arrington" on Justia Law

The Supreme Court affirmed the judgment the district court denying postconviction relief sought by Defendant without conducting an evidentiary hearing, holding that the district court did not abuse its discretion by failing to hold an evidentiary hearing on Defendant's claims.Defendant was convicted of three counts of first-degree murder and sentenced to death on each murder conviction. Defendant later filed what the district court referred to as his fifth postconviction motion, alleging (1) after the Legislature passed L.B. 268 abolishing the death penalty and when L.B. 268 was subsequently repeated by public referendum, his constitutional rights were violated; and (2) he was constitutionally ineligible for imposition of the death penalty under Atkins v. Virginia, 536 U.S. 304 (2002). The court summarily denied relief on both claims. The Supreme Court affirmed, holding (1) the district court properly found that Defendant's Atkins claim was both procedurally barred and time barred; and (2) Defendant's L.B. 268 claim was meritless. View "State v. Lotter" on Justia Law

The Seventh Circuit affirmed the judgment of the district court entering judgment upon the jury's verdict in favor of Paul Reina on his claim that Walmart violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), (b) and acted maliciously or in reckless disregard of Reina's rights, holding that the district court did not abuse its discretion.Reina, who was deaf and legally blind, worked as a cart attendant for Walmart for almost twenty years. After providing Reina with a job coach, Walmart eventually ended Reina's employment. Reina filed an administrative charge with the Equal Employment Opportunity Commission (EEOC), which sued Walmart for violating the ADA. The jury concluded that Walmart violated the ADA by refusing Reina a reasonable accommodation in the form of a full-time job coach and acted maliciously or in reckless disregard of Reina's rights. The jury awarded Reina $200,000 in compensatory damages and $5 million in punitive damages. The Third Circuit affirmed, holding (1) the district court properly denied Walmart's motion for judgment as a matter of law; and (2) the district court did not abuse its discretion by declining to issue an injunction against Walmart as proposed by the EEOC. View "Equal Employment Opportunity Commission v. Wal-Mart Stores, Inc." on Justia Law

Plaintiff was imprisoned at Hays State Prison after he was convicted of voluntary manslaughter. While he lived there, Plaintiff killed another inmate by stabbing him with a knife during a fight. Plaintiff disagreed with prison policy regarding shower security. Plaintiff believed that the restrictions infringed his constitutional rights.   To challenge these policies and raise a host of other complaints, Plaintiff sued several prison officials under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. Section 2000cc–1, and 42 U.S.C. Section 1983, seeking declaratory, injunctive, and monetary relief. In his complaint, Plaintiff claimed that the shower policies intruded on his First and Fourteenth Amendment rights. The district court granted summary judgment to the prison officials on his shower policy claims.   The Eleventh Circuit affirmed the district court’s grant of summary judgment. The court explained to test whether a state prison regulation violates an inmate’s constitutional rights, courts ask whether the regulation is reasonably related to a legitimate penological interest. That inquiry is intended to ensure that prison officials respect constitutional boundaries without frustrating their efforts to fulfill the difficult responsibility of prison administration.   Here, although the inmate suggests ways the prison could make an exception to accommodate his religious requests, he does not show that the policies were unconstitutional in the first place. And even if they were, qualified immunity would protect the officials because the types of shower rights the inmate seeks are not clearly established. View "Hjalmar Rodriguez, Jr. v. Edward H. Burnside, et al." on Justia Law

The Court of Appeal affirmed the judgment of the trial court convicting Defendant of the involuntary manslaughter of his girlfriend, holding that no violation of Brady v. Maryland, 373 U.S. 83 (1963), occurred in this case.During trial, the county medical examiner opined that the victim had been beaten to death, and the district court relied on that testimony in arguing that Defendant beat his girlfriend to death, thereby committing first-degree murder. On appeal, Defendant challenged the trial court's failure to disclose certain portions of redacted memoranda written by the office of the district attorney as material relevant to impeachment of the medical examiner's trial testimony. The Court of Appeal affirmed, holding that, although portions of the redacted memoranda qualified as impeachment material under Brady, the failure to disclose them was not material to the outcome at trial. View "People v. Deleoz" on Justia Law

Plaintiff sued Defendant officer, under 42 U.S.C. Section 1983, alleging that Defendant violated Plaintiff’s Eighth and Fourteenth Amendment rights when the officer used a roadblock to stop Plaintiff, who was suspected of committing a minor traffic violation, from fleeing on a bicycle. The district court construed Plaintiff’s allegations as asserting a Fourth Amendment excessive-force claim and found that his claim was plausible.   The Ninth Circuit reversed the district court’s denial of qualified immunity Defendant. The court held that the question of whether Defendant used excessive force against Plaintiff would be a question for a factfinder. The roadblock was a use of intermediate force that was capable of inflicting significant pain and causing serious injury. Given the circumstances, a jury could conclude that Defendant should have taken additional steps to stop Plaintiff before using an intermediate level of force given Plaintiff’s minor offense and the lack of any safety risk to de Defendant or anyone else. However, even if Defendant did use excessive force, the law as it existed at the time of the incident did not clearly establish that his actions violated the Fourth Amendment. Therefore, Defendant was entitled to qualified immunity. View "PRESTON SEIDNER V. JONATHAN DE VRIES" on Justia Law

Plaintiff was diagnosed with a reducible ventral hernia while detained awaiting trial at the Greene County Justice Center in Missouri. Although his hernia could be repaired through surgery, Plaintiff was unable to prepay the fee required by the outside surgeon and thus the hernia was not repaired during his detention.   Plaintiff filed suit under 42 U.S.C. Section 1983 against the Greene County Sheriff’s Department and its contract healthcare service provider, Advanced Correctional Healthcare, Inc. (ACH), as well as several individuals employed by those entities (collectively, jail officials). Plaintiff claimed that the jail officials were deliberately indifferent to his serious medical need. The district court granted summary judgment in favor of Defendants.   The Fourth Circuit affirmed the grant of summary judgment. The court explained that to establish deliberate indifference Plaintiff was required to show (1) that he suffered from an objectively serious medical need and (2) that the jail officials had actual knowledge of that need but deliberately disregarded it. The court explained that Plaintiff submitted no medical or expert evidence that any delay in his hernia repair surgery created any excessive risk or harm. Plaintiff argued that his own claims of pain and suffering constitute the verifying medical evidence needed to show harm from the delay. Without corroborating evidence of symptoms, however, self-reported assertions of pain are insufficient to survive summary judgment.   Further, despite Plaintiff’s subjective reports of pain, objective observations did not indicate that he was in severe pain or forced to limit his activities. Thus, the court held that Plaintiff has not demonstrated that jail officials disregarded a known risk to his health. View "Michael Hancock v. Jim Arnott" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions on the grounds that his counsel had been ineffective, holding that errors on the part of trial counsel did not prejudice Defendant.Defendant was convicted of murder and several related charges. The court of appeals vacated the convictions, determining that trial counsel was ineffective in failing to object to the use of evidence about Defendant's silence while being arrested and in not objecting to the manslaughter jury instruction, prejudicing Defendant. The Supreme Court reversed, holding (1) defense counsel was ineffective for not objecting to the manslaughter jury instruction, which incorrectly shifted the burden of proof for imperfect self-defense, but the error was not prejudicial; and (2) assuming that defense counsel was ineffective for failing to object to commentary by the prosecution in Defendant's silence after arrest, the error was not prejudicial. View "State v. Bonds" on Justia Law

The Supreme Court affirmed the order of the circuit court denying the guilt-phase claims Kim Jackson raised in his motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and denied Jackson's petition for a writ of habeas corpus, holding that Jackson was not entitled to relief.After a jury trial, Jackson was found guilty of first-degree murder and sentenced to death. The Supreme Court affirmed. Jackson subsequently filed a postcondition motion raising more than twenty claims for relief. The circuit court vacated Jackson's death sentence under Hurst v. State, 202 So. 3d 40 (Fla. 2016), and otherwise affirmed. The Supreme Court affirmed and denied habeas corpus relief, holding (1) a due process claim for preindictment delay requires a showing of substantial prejudice to the defendant and bad faith on the part of the State; (2) as to two of Jackson's claims of ineffective assistance of counsel this Court assumed deficient performance but found no prejudice; and (3) Jackson was not entitled to a writ of habeas corpus. View "Jackson v. State" on Justia Law