Justia Civil Rights Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing the trial court's denial of Defendant's motion to suppress, holding that the trial court's findings of fact were supported by competent evidence and that Defendant's search and seizure did not violate the Fourth Amendment of the United States Constitution.Following the trial court's denial of Defendant's motion to suppress Defendant pleaded guilty to various drug offenses. The court of appeals vacated the convictions, concluding that the trial court erred in denying Defendant's motion to suppress. The Supreme Court reversed, holding (1) competent evidence supported the trial court's findings of fact; (2) Defendant was lawfully detained pursuant to Michigan v. Summers, 452 U.S. 692 (1981) and State v. Williams, 490 S.E.2d 583 (N.C. 1997); and (3) the frisk of Defendant was reasonable under the totality of the circumstances. View "State v. Tripp" on Justia Law

The Supreme Court held that juvenile offenders who have received sentences of life imprisonment with the possibility for parole must have the opportunity to seek an early release afforded by the prospect of parole after serving no more than forty years' incarceration.Defendant was fifteen years old when he received sentences of 240 to 348 months' imprisonment for a rape conviction and life imprisonment with the possibility of parole for a murder conviction, ordered by the trial court to run consecutively. The Supreme Court held that, while juvenile offenders who have received sentences of life imprisonment with the possibility of parole are not guaranteed parole at any point during their terms of incarceration, to compel Defendant to serve a term of incarceration in excess of forty years upon the trial court's determination that Defendant was neither incorrigible nor irredeemable would constitutionally constitute a de facto life sentence. View "State v. Conner" on Justia Law

The Supreme Court vacated the decision of the court of appeals dismissing Defendant's appeal of his conviction for two counts of manufacturing methamphetamine, holding that the trial court erred in denying Defendant's motion to suppress.Defendant filed two motions to suppress evidence obtained during two searches of Defendants home in 2014 and 2015. Both motions were denied. Defendant appealed, but the court of appeals dismissed the appeal and denied his petition for a writ of certiorari. The Supreme Court remanded the case for reconsideration in light of State v. Ledbetter, 371 N.C. 192 (2018) and State v. Stubbs, 368 N.C. 40 (2015). On remand, the court of appeals again denied the petition, indicating that Defendant's failure to provide timely notice of his intent to appeal was fatal to his petition. The Supreme Court vacated the decision below, holding that the court of appeals had the jurisdiction and authority to issue the writ of certiorari. View "State v. Killette" on Justia Law

Plaintiffs are practicing Muslims who believe that they are required under the precepts of their religion to perform five daily congregational prayers with as many other Muslims as are available and wish to participate. Plaintiffs alleged that while they were incarcerated at the Federal Correctional Institution in Danbury, Connecticut ("FCI Danbury"), wardens enforced a policy that restricted prayer in groups of more than two to the prison's chapel.   Plaintiffs filed suit against defendant prison officials seeking injunctive relief and damages on the grounds that FCI Danbury's communal prayer policy violated the Religious Freedom Restoration Act ("RFRA") and the Free Exercise Clause of the First Amendment to the United States Constitution.   The district court granted Defendants' motion to dismiss Plaintiffs' Second Amended Complaint (“SAC”) in large part, but declined to dismiss Plaintiffs' RFRA claims for damages against Defendants in their individual capacities, holding that qualified immunity was not available to the wardens at the motion-to-dismiss stage.   The Second Circuit affirmed the district court’s ruling, concluding that the wardens are not entitled to qualified immunity at this stage of the proceedings because the pleadings do not establish that their enforcement of the policy against Plaintiffs was in service of a compelling interest, and it was clearly established at the time of the violation that substantially burdening an inmate's religious exercise without justification violates RFRA. The court explained that a reasonable officer should have known, based on clearly established law, that denying a Muslim inmate the ability to engage in group prayer without any justification or compelling interest, as alleged in the SAC, violates RFRA. View "Sabir v. Williams" on Justia Law

The Supreme Court held that the Iowa Constitution is not the source of a fundamental right to an abortion necessitating a strict scrutiny standard of review for regulations affecting that right.In Planned Parenthood of the Heartland, Inc. v. Iowa Board of Medicine (PPH I), 865 N.W.2d 252 (Iowa 2015), the Supreme Court applied the federal undue burden test established in Planned Parenthood of Southeastern Pennsylvania v. Casey, 505 U.S. 833 (1992), under the Iowa Constitution. In Planned Parenthood of the Heartland v. Reynolds (PPH II), 915 N.W.2d 206, (Iowa 2018), the Supreme Court rejected the undue burden test and found that the due process clause of the Iowa Constitution protected abortion as a fundamental right. In 2020, the general assembly added a mandatory 24-hour waiting period for abortion to pending legislation limiting courts' ability to withdraw life-sustaining procedures. Planned Parenthood successfully sued in district court to block the statute from taking effect. The district court granted summary judgment for Planned Parenthood. The Supreme Court reversed, holding (1) PPH II is overruled; and (2) therefore, the Casey undue burden test applied in PPH I remains the governing standard. View "Planned Parenthood of the Heartland, Inc. v. Reynolds ex rel. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for drug- and firearm-related offenses, holding that the district court did not abuse its discretion by granting defense counsel's motion to withdraw and did not err in concluding that Defendant knowingly, voluntarily, and intelligently waived his right to counsel.The district court granted defense counsel's motion to withdraw from representation of Defendant approximately three weeks before Defendant's speedy trial expiration date. Although the district court offered to appoint another attorney to represent Defendant, Defendant demanded that he represent himself with the assistance of standby counsel. After conducting colloquies the district court allowed Defendant to proceed pro se with the assistance of standby counsel. The Supreme Court affirmed Defendant's convictions, holding that the district court (1) did not abuse its discretion by granting defense counsel’s motion to withdraw based on defense counsel’s statements that professional considerations required termination of the representation; and (2) correctly concluded that Defendant knowingly, intelligently, and voluntarily waived his right to counsel after engaging in a thorough colloquy. View "State v. Miller" on Justia Law

In 2004, Watkins was convicted of possessing crack cocaine with intent to distribute. He received a mandatory life sentence based on three prior convictions for “felony drug offenses.” After multiple unsuccessful collateral attacks, Watkins filed this 28 U.S.C. 2241 petition, citing the Supreme Court’s 2016 “Mathis” decision and arguing that two of his prior convictions did not qualify as predicate felony drug offenses under 21 U.S.C. 841(b)(1)(A), so his enhanced sentence was unlawful. Following enactment of the First Step Act of 2018, Watkins applied for relief under that statute, was resentenced to time served, and was released from prison. He is currently serving a reduced term of supervised release.The Seventh Circuit remanded with instructions to dismiss the 2241 petition as moot. Watkins can only speculate that Watkins might benefit from a decision on the merits; the mere possibility that a decision might influence the court’s determination on remand concerning his term of supervised release is not enough to keep the case alive. Intervening case law, combined with the government’s concession, should be more than enough to make clear in any future section 3583(e) proceedings that Watkins was not properly subject to a mandatory life sentence. View "Watkins v. United States District Court for the Central District of Illinois" on Justia Law

In 2005, Adolphe was found murdered in front of his apartment building. Adolphe and Carr had been dating. Carr, age 16, was arrested and entered an Alford plea in 2008 to second-degree manslaughter, conspiracy to commit robbery, conspiracy to commit burglary, and tampering with physical evidence. She was paroled in 2009 and discharged in 2018. In 2019, Kentucky Governor Bevin granted Carr “the full and unconditional pardon she has requested.”A year later, Carr sued under 42 U.S.C. 1983, alleging that the defendants fabricated evidence, coerced false statements, and withheld exculpatory evidence. The district court dismissed Carr’s complaint, finding that her section 1983 claims were not cognizable under the Supreme Court’s “Heck” decision. The Sixth Circuit reversed. While a full pardon does not always indicate that the individual is innocent, Heck did not impose a prerequisite of innocence to seek relief under section 1983; a full pardon in Kentucky removes all legal consequences so that a plaintiff can proceed with her section 1983 claims. View "Carr v. Louisville-Jefferson County" on Justia Law

The Hopkinses kept cattle on their Marshall County, Tennessee farm. Detective Nichols received a complaint about the treatment of those cattle, drove by, and observed one dead cow and others that did not appear to be in good health. Nichols returned with Tennessee Department of Agriculture Veterinarian Johnson. Wearing his gun and badge, Nichols knocked and. according to Mrs. Hopkins, “demanded that [she] escort them to see the cattle,” refusing to wait until Mr. Hopkins returned or until she fed her children. Johnson completed a Livestock Welfare Examination, as required by law, noting that the cattle were not in reasonable health, that they lacked access to appropriate water, food, or shelter, and that major disease issues were present; she determined that probable cause for animal cruelty existed. Nichols returned to the Hopkins’s farm several times and discovered a sinkhole containing the remains of multiple cattle. Nichols and Sheriff Lamb eventually seized the cattle without a warrant and initiated criminal proceedings. The cattle were sold.The Sixth Circuit affirmed the denial of a motion for qualified immunity in a suit under 42 U.S.C. 1983. Forced compliance with orders is a Fourth Amendment seizure; words that compel compliance with orders to exit a house constitute a seizure. While the open fields doctrine allowed the officers to lawfully search the farm, it did not give them lawful access to seize the cattle; they lacked exigent circumstances when they seized the cattle. View "Hopkins v. Nichols" on Justia Law

A county chapter of the NAACP and four individual Plaintiffs brought suit against the district attorney (“DA”) for the Mississippi counties in which they live, claiming he regularly discriminates against black potential jurors by striking them from juries because of their race. The Plaintiffs asserted violations of their own constitutional rights to serve on juries. The district court determined that it should apply one of the Supreme Court’s abstention doctrines and dismissed the case.   The Fifth Circuit affirmed holding that Plaintiffs have not alleged a certainly impending threat or a substantial risk to their rights that would satisfy the requirements of Article III. The court explained that to prevail on a claim for prospective equitable relief, a plaintiff must demonstrate continuing harm or a “real and immediate threat of repeated injury in the future. Further, the Fourteenth Amendment protects the right of a citizen not to be excluded from a petit jury because of his or her race. A juror who alleges being struck from a jury because of race has alleged a cognizable injury for purposes of Article III standing.Here, Plaintiffs allege that their injury is the imminent threat that the DA will deny them an opportunity for jury service by excluding them because of their race. However, save one, none of the Plaintiffs have ever been struck from a jury by the DA. Further, members of the county chapter cannot demonstrate an imminent threat that they will be struck unconstitutionally from a petit jury by the DA. Thus, Plaintiffs have not established standing. View "Attala County, MS Branch v. Evans" on Justia Law