Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment and sentence of the district court in this criminal case, holding that the district court adequately considered evidence of Defendant's post-offense rehabilitation under Miller v. Alabama, 567 U.S. 460 (2012), and imposed a constitutional sentence by striking a parole restriction.When he was seventeen years old, Defendant was charged with burglary and three counts of deliberate homicide. Defendant was convicted of all counts and sentenced to three consecutive life sentences without parole. Defendant later filed a successful postconviction petition seeking resentencing under Miller. After a resentencing hearing, the district court sentenced Defendant to three consecutive life terms at MSP without the possibility of parole. The Supreme Court remanded the case. On remand, the district court resentenced him to three life sentences and did not restrict Defendant's eligibility for parole. The Supreme Court affirmed, holding that the district court complied with the Court's instructions on remand in Keefe II and imposed a legal sentence. View "Keefe v. State" on Justia Law

The First Circuit affirmed the district court's judgment dismissing Plaintiffs' lawsuit asserting race-based discrimination and retaliation in violation of Title VII of the Civil Rights Act, holding that the district court did not err in dismissing the suit for failure to state a claim.Plaintiffs represented a putative class of employees employed by Whole Foods and Amazon who were disciplined for wearing face masks with the message "Black Lives Matter." In their lawsuit, Plaintiffs alleged that the manner in which their employers enforced a previously unenforced dress code policy constituted race-based discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964. The district court dismissed all claims. The First Circuit affirmed, holding that Plaintiffs did not adequately plead claims for racial discrimination and retaliation under Title VII. View "Frith v. Whole Foods Market, Inc." on Justia Law

Plaintiff was transferred from a class where she instructed emotionally disturbed (“ED”) children to a class where Plaintiff worked with children with moderate intellectual disabilities. Plaintiff alleged that one of her students sexually harassed her between fall 2018 through mid-March 2019. This student, S.M., was an eight-year-old boy diagnosed with Down’s Syndrome and Attention Deficit Hyperactivity Disorder (“ADHD”). Although the teacher in the classroom recorded the incidents in her notes, or “point sheets,” where she detailed each student’s daily behavior, Plaintiff claims the teacher was generally dismissive of her concerns. After exhausting her remedies with the United States Equal Employment Opportunity Commission, Plaintiff filed suit against the Chesterfield County School Board (“the School Board”) alleging that she was subjected to a sexually hostile work environment in violation of Title VII.   The district court granted the School Board’s motion for summary judgment. At issue on appeal is whether the district court erred in dismissing Plaintiff’s hostile work environment claim on summary judgment. The Fourth Circuit affirmed, finding that the record does not support a prima facie case for hostile work environment sexual harassment. The court explained that Plaintiff cannot primarily rely upon her own statements to argue that S.M.’s conduct surpassed what could be expected of an eight-year-old child with his disabilities after two special education experts testified that it did not—instead, she is required by law to demonstrate it. Further, even if Plaintiff established that S.M. targeted her because of sex, she would still be unable to meet the third required element—that is, show that S.M.’s conduct rose to the level of severe or pervasive. View "Regina Webster v. Chesterfield County School Board" on Justia Law

Plaintiff wanted to share his religious message on the public streets and sidewalks of Fort Myers Beach, Florida (“the Town”). However, to reduce visual blight and increase traffic safety, Chapter 30 of the Town’s Land Development Code (hereinafter, “the Ordinance”) prescribed an elaborate permitting scheme for all signs to be displayed within the Town. Among other things, the Ordinance has entirely prohibited some categories of signs, including portable signs. Plaintiff carried a portable sign to spread his message and, after receiving a written warning, the Town issued him a citation. He sued the Town and the officers who cited him in their individual and official capacities for declaratory, injunctive, and monetary relief, alleging violations of the First Amendment, the Equal Protection Clause, and Florida’s Religious Freedom Restoration Act. The district court denied Plaintiff’s motion for a preliminary injunction, concluding that the Ordinance’s ban on portable signs was content-neutral and narrowly tailored to serve a significant governmental interest.   The Eleventh Circuit reversed the judgment. The court explained that the Town’s complete ban on all portable signs carried in all locations almost surely violates the First Amendment. The court wrote that the most natural reading of the Ordinance leads to the conclusion that all portable signs are banned--regardless of whether they are political, religious, advertising a garage sale, or an open house. The Ordinance’s ban on portable signs is content-neutral. But portable, handheld signs still are a rich part of the American political tradition and are one of the most common methods of free expression. The ban on these signs leaves the residents without an effective alternative channel of communication. View "Adam Lacroix v. Town of Fort Myers Beach, Florida, et al." on Justia Law

Lee‐Kendrick was charged with sexual assault of girls under the age of 16: his biological daughter; his girlfriend’s daughter, A.W.; and a friend. Lee‐Kendrick testified that the accusations arose only after he started taking away their cell phones and allowances. There was no physical evidence. The jury found him guilty. Lee‐ Kendrick unsuccessfully sought a new trial, arguing that his trial counsel provided ineffective assistance by not objecting to certain prejudicial cross‐examination.In post-conviction motions, Lee‐ Kendrick argued his postconviction counsel provided ineffective assistance by failing to raise his trial counsel’s ineffectiveness in not calling as a witness A.W.'s friend, Keeler. Lee‐Kendrick cited a memorandum from a Wisconsin State Public Defender's investigator, recounting an interview in which Keeler said that A.W. told Keeler of her plan to get Lee‐Kendrick in trouble. The state trial court did not find Lee‐Kendrick’s claims procedurally barred for having not been raised on direct appeal but applied the “Strickland” standard to reject Lee‐Kendrick’s arguments. The Wisconsin Court of Appeals affirmed, going beyond his failure to raise the argument on appeal and reasoning that the attorney’s decision was not prejudicial because Keeler had no direct knowledge of the sexual assaults; Keeler’s testimony would have been inconsistent with the defense theory.The Seventh Circuit affirmed the denial of habeas relief. His claim concerning failure to call Keeler was denied on an adequate and independent state‐law ground and is procedurally defaulted. That default is not excused by cause and prejudice. View "Lee-Kendrick v. Eckstein" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony possession of marijuana, entered following Defendant's conditional guilty plea, holding that the initial traffic stop of Defendant in this case comported with the requirements of the Fourth Amendment to the United States Constitution.In denying Defendant's motion to suppress, the trial court concluded that the initial traffic stop was justified as a drug trafficking investigation. Defendant appealed, arguing that the district court erred in concluding the officer had reasonable suspicion to stop Defendant based on the collective knowledge doctrine. The Supreme Court affirmed, holding that the initial stop was legally justified under the Fourth Amendment, and therefore, the district court did not err in denying Defendant's motion to suppress. View "Guandong v. State" on Justia Law

The Supreme Court determined that a warrantless search conducted in this case did not comport with the Fourth Amendment under the "single-purpose-container exception" to the warrant requirement, holding that when police search a bookbag in a home under circumstances that do not give rise to any exigency they must first obtain a warrant.After he was charged with illegal possession of drugs Defendant filed a motion to suppress, arguing that the warrantless search of the book bag conducted by a law enforcement officer was unlawful. The trial court denied the motion, concluding that the warrantless search was lawful because the book bag was in plain view and the officer had probable cause to suspect it contained contraband. The court of appeals affirmed. The Supreme Court reversed, holding (1) absent exigent circumstances, the search of a closed container requires a warrant; and (2) the single-purpose-container exception to the warrant did not apply in this case because a bookbag is not a single-purpose drug container. View "State v. Burroughs" on Justia Law

John Jay’s assistant coach (“Coach”) was “increasingly agitated, angry and enraged over his belief that the referee crew was making ‘bad calls,’” and over “alleged racial comments” Plaintiff, a referee, had directed at players. Coach told John Jay players “to hit” Plaintiff because “he need[ed] to pay the price.” The Coach pleaded guilty to assault causing bodily injury, affirming that he did “intentionally, knowingly, or recklessly cause bodily injury to Plaintiff by striking him.” This civil rights suit, filed in state court and later removed to federal court, followed.   The Fifth Circuit affirmed the dismissal of the school district. The court held no policy or custom of Northside Independent School District directed the assault on Plaintiff—quite the opposite, the Coach had gone rogue in ordering the assault—so the district is not liable under section 1983.   But the state-created-danger theory does not even fit this situation in which a public employee ordered private actors to commit an assault. Instead, the theory applies when a state actor creates a dangerous condition that results in harm. It involves a mens rea of deliberate indifference, not the intentional infliction of harm. Instead, it is an example of a public official’s ordering private actors to engage in the conduct. The law has long recognized that state action exists when a state actor commands others to commit acts as much as when the state actor commits those act. Further, the court left it to the district court to determine complaint has alleged a violation of clearly established due process law. View "Watts v. Northside Indep Sch Dist, et al" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that the conduct of two court personnel while sharing a nonpublic courthouse elevator with a jury during trial triggered a rebuttable presumption of prejudice against Defendant, holding that the court of appeals did not err.The court personnel in this case - a uniformed highway patrolman and a court IT technician - told the jurors, in so many words, to find Defendant guilty and to "hang him." The trial court bailiff also stood in the elevator but did not intervene in the exchange. The court of appeals reversed Defendant's conviction and remanded the case for a new trial. The Supreme Court affirmed, holding that the impermissible contact violated Defendant's right to an impartial jury and triggered a rebuttable presumption that Defendant was prejudiced as a result. The Court remanded the case to the district court for a determination of whether the State met its burden to rebut this presumption. View "State v. Soto" on Justia Law

Greenpoint Tactical Income Fund and its affiliates and managers were the subjects of an FBI investigation into suspected fraud, particularly with respect to Greenpoint’s asset valuation practices. The investigation led to the issuance of a search warrant for plaintiffs’ properties and the seizure of some assets. Plaintiffs filed suit against Agent Pettigrew and Assistant United States Attorney Halverson, alleging violations of their Fourth Amendment rights by submitting a false and misleading affidavit in support of the search warrant. They sought damages. The district court dismissed the suit, concluding that plaintiffs were seeking to extend “Bivens” to a “new context” and that “special factors” counseled hesitation in doing so.The Seventh Circuit affirmed the dismissal on different grounds. Even assuming that Bivens can reach the Fourth Amendment violations alleged here, Halverson is entitled to absolute prosecutorial immunity and Agent Pettigrew is entitled to qualified immunity. There is no allegation that Halverson was interviewing witnesses himself, was actively involved in the investigation as it was unfolding, or personally vouched for the truth of the allegations in Pettigrew’s affidavit. A reasonable agent in Pettigrew’s position could believe the allegations amounted to probable cause. View "Greenpoint Tactical Income Fund LLC v. Pettigrew" on Justia Law