Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court denying Defendant's motion to suppress location data obtained from the police's search of his real-time cell-site location information (CSLI) and the evidence obtained from the search, holding that suppression was required.Defendant entered a conditional guilty plea to one count of first-degree robbery, one count of possession of a handgun by a convicted felon, and one count of receiving stolen property. The court of appeals reversed, concluding that the trial court erred in denying Defendant's motion to suppress because the police's acquisition of Defendant's real-time CSLI constituted a warrantless, unreasonable search. The Supreme Court affirmed, holding that the officers illegally obtained Defendant's real-time CSLI and that the evidence obtained therefrom should be excluded from evidence. View "Commonwealth v. Reed" on Justia Law

In 2015, Aljohani was indicted on five counts of first-degree murder in connection with the stabbing death of Talal and one count of armed robbery. The circuit court denied a motion to suppress evidence. The court concluded that the officers’ entry into an apartment fell “squarely within the community caretaking function.” In 2018, Aljohani was convicted and sentenced to 23 years in prison. The appellate court affirmed, citing the emergency aid exception to the warrant requirement.The Illinois Supreme Court affirmed, finding that the evidence was sufficient to prove guilt beyond a reasonable doubt. The police officers had reasonable grounds to believe an emergency existed, having responded to a 911 call about a suspected battery in progress and spoken to a witness, who was “adamant” that someone was seriously hurt. The officers saw an apartment door “wide open,” received no response, and found the victim unresponsive on a bed. The totality of the circumstances at the time of entry provided an objective, reasonable basis for believing someone was injured inside the apartment. View "People v. Aljohani" on Justia Law

In 2017, Brown was charged with violating section 2(a)(1) of the Firearm Owners Identification Card Act (430 ILCS 65/2(a)(1)), which requires a person who possesses a firearm in Illinois to have a Firearm Owners Identification (FOID) card issued by the State Police. Brown challenged section 2(a)(1) as unconstitutional as applied under the Second Amendment. The circuit court dismissed the charge, finding that the legislature did not intend for the FOID Act to apply in a person’s home because “such an interpretation would lead to absurd and unworkable results.”The Illinois Supreme Court stated: “The circuit court’s ruling that section 2(a)(1) … is unconstitutional as applied was not necessary to the resolution of this case. Therefore, we remand this cause … direct that the order … be vacated." When the cause was remanded, the matter proceeded before a new judge, who adopted the reasoning of an Illinois Supreme Court dissent and again found the section unconstitutional as applied.The Illinois Supreme Court again vacated and remanded. The circuit court had no authority to set aside the directions on remand and enter a different order. The mandate was “precise and unambiguous.” On remand, “the circuit court shall not entertain any motion from any party, nor take any action other than entering the modified order.” View "People v. Brown" on Justia Law

N.J., in seventh grade, went to school wearing a T-shirt displaying a Smith & Wesson logo, with an image of a revolver. A.L., a high school student, went to school wearing a T-shirt bearing the logo of a gun-rights group, incorporating an image of a handgun. Administrators at both schools barred the boys from wearing the shirts. Neither school’s dress code expressly bans clothing with images of firearms; the dress codes prohibit “inappropriate” attire, which the administrators interpreted to bar any clothing with an image of a firearm. The students brought separate lawsuits alleging violations of their free-speech rights under 42 U.S.C. 1983.The district court consolidated the cases and granted the school administrators summary judgment, declining to apply the Supreme Court’s “Tinker” precedent, which established the legal standard for student-speech cases. The court applied the standard for speech restrictions in a nonpublic forum—the most lenient test— and upheld the administrators’ actions as viewpoint neutral and reasonable.The Seventh Circuit remanded. This is not a speech-forum case. Tinker provides the legal standard: restrictions on student speech are constitutionally permissible if school officials reasonably forecast that the speech “would materially and substantially disrupt the work and discipline of the school” or invade the rights of others. Although this test is deferential to school officials and is “applied in light of the special characteristics of the school environment,” it is stricter than the test for speech restrictions in a nonpublic forum. View "N.J. v. Sonnabend" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's petition for habeas corpus, in which he alleged ineffective assistance of counsel, holding that Appellant failed to establish that his counsel's performance was deficient under Strickland v. Washington, 466 U.S. 668 (1984).After a retrial, Appellant was convicted of two counts of attempting to kill a federal witness with intent to prevent testimony and communication with law enforcement. The First Circuit affirmed. Appellant later filed a motion under 28 U.S.C. 2255 to vacate his conviction based on ineffective assistance of counsel. The district court denied relief. The First Circuit affirmed, holding that Appellant's claims of ineffective assistance of counsel were unavailing. View "Watson v. United States" on Justia Law

Plaintiffs, seven adults who claimed they were molested by a priest when they were children, brought suit against The Roman Catholic Archbishop of Los Angeles and related parties ("Defendants"). The Plaintiffs' claims were that the Defendants ratified the assaults and acted negligently in failing to supervise the priest who committed the assaults.In response, Defendants moved to strike the complaint, claiming that some of the acts that allegedly ratified the priest's conduct, as well as those serving as the basis for the allegations of negligence, constituted speech and litigation conduct that was protected under California's anti-SLAPP law (Code Civ. Proc. § 425.16). The district court rejected Defendants' anti-SLAPP motion.The Second Appellate District affirmed. As to the ratification claims, the court held that Defendants mischaracterized Plaintifffs' complaint, "cherry-picking allegations of litigation conduct, and, without support, suggesting that they are the only allegations incorporated by reference into the sexual abuse cause of action."As to the negligence claims, Defendants too narrowly construed Plaintiffs' complaint, focusing only on what Defendants claim was protected speech. Any allegations in Plaintiffs' complaint that may have been "conclusory" when taken out of context, were supported by factual allegations earlier in the complaint. View "Ratcliff v. Roman Catholic Archbishop of L.A." on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three counts of first-degree statutory sodomy and three counts of incest and sentencing him to a total of eighty-seven years' imprisonment, holding that there was no error.On appeal, Defendant argued that the circuit court erred in admitting evidence pursuant to Mo. Const. art. I, 18(c), overruling objections to the State's closing argument, admitting expert testimony and particular exhibits, and finding sufficient evidence to support the convictions. The Supreme Court affirmed, holding that there was no error, plain or otherwise, or abuse of discretion in the proceedings below. View "State v. Minor" on Justia Law

Defendants dismissed Plaintiff from two graduate nursing studies programs. She sued, claiming that her dismissal violated the Americans with Disabilities Act (“ADA”), the Rehabilitation Act, and the Due Process Clause. The district court refused to dismiss some of her claims. The Defendants appealed part of that order, contending that they have sovereign immunity from Plaintiff’s ADA claims and that she failed to state Fourteenth Amendment claims.   The Fifth Circuit dismissed Defendants' appeal in part finding that the court lacks appellate jurisdiction over the Fourteenth Amendment claims. The court affirmed the order in part and reversed the order in part, concluding that Plaintiff stated some Title II claims but not all of the claims that the district court refused to dismiss. Defendants were not entitled to sovereign immunity at this stage of the litigation because Plaintiff’s allegations did not permit the court to assume that Defendants did not violate her due-process rights. The court explained that it has appellate jurisdiction over only the denial of sovereign immunity from Plaintiff’s ADA claims. The court wrote it must assume that Plaintiff’s allegations are true and draw all reasonable inferences in her favor. The state may or may not be correct that its rebuttal evidence vitiates any inference that Defendants discriminated against Plaintiff because of her disability. But the pleading stage was not the right time to raise those contentions. Although the court has done so in the past, Plaintiff’s allegations do not permit the court to assume that the Due Process Clause was not violated. View "Pickett v. Texas Tech Univ" on Justia Law

The en banc Ninth Circuit court dismissed as moot an appeal from the district court’s summary judgment in favor of California Governor Newsom and state officials in an action brought by a group of parents and a student alleging Defendants violated federal law when they ordered schools to suspend in-person instruction in 2020 and early 2021, at a time when California was taking its first steps of navigating the Covid-19 pandemic.   The en banc court held that this was a classic case in which, due to intervening events, there was no longer a live controversy necessary for Article III jurisdiction. Nor was there any effective relief that could be granted by the court. The parents had not brought a claim for damages; they sought a declaratory judgment that Governor Newsom’s executive orders, to the extent they incorporated guidance on school reopening, were unconstitutional. Relatedly, they sought an injunction against the 2020-21 Reopening Framework. But Governor Newsom has rescinded the challenged executive orders, and the 2020-21 Reopening Framework has been revoked. Schools now operate under the 2021-22 Guidance, which declares that all schools may reopen for in-person learning. And the parents conceded that, since April 2021, there has been no “state-imposed barrier to reopening for in-person instruction.” The actual controversy has evaporated.The en banc court rejected Plaintiffs’ assertion that the case survived under two exceptions to mootness: the voluntary cessation exception and the capable of repetition yet evading review exception. Neither exception applied. View "MATTHEW BRACH V. GAVIN NEWSOM" on Justia Law

Inmate Rivera was temporarily transferred in order to represent himself in a trial challenging his conditions of confinement. He was assigned to the Restricted Housing Unit (RHU) from which inmates may access a “mini law library.” Rivera’s trial was scheduled to begin on a Monday. On Friday, his request for continuing access to the library throughout his trial was approved. The library, however, did not contain any physical books, only two computers. Both were inoperable. Rivera had no way to access the Federal Rules of Civil Procedure, the Rules of Evidence, and the court rules. Rivera’s request to borrow paper copies from the main law library was summarily denied. The judge refused to admit his evidence on hearsay grounds. The jury entered a defense verdict. According to Rivera, access to the Rules would likely have changed the outcome of his trial.The Third Circuit affirmed the dismissal of Rivera’s 42 U.S.C. 1983 suit on qualified immunity grounds. At the time of the alleged violation, Supreme Court and Third Circuit precedents had not clearly established a prisoner’s right to access the material after he filed a complaint. “Going forward, however, there should be no doubt that such a right exists. The ability of a prisoner to access basic legal materials in a law library … does not stop once a prisoner has taken the first step towards the courthouse’s door.” View "Rivera v. Monko" on Justia Law