Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment convicting Defendant of one count of murder, holding that Defendant was not entitled to relief on any of his allegations on appeal.Specifically, the Supreme Court held that the appellate court correctly concluded that the trial court (1) did not violate Defendant's Sixth Amendment right to present a defense by excluding from evidence a statement purportedly made by an unknown female bystander and an autopsy toxicology report; (2) did not violate Defendant's right to due process by declining to give a jury instruction on self-defense; and (3) did not abuse its discretion by declining to sanction the state for its late disclosure of the murder weapon and related expert reports by excluding this evidence or dismissing the murder charge. The Court further cautioned the State regarding the late disclosure of evidence. View "State v. Hargett" on Justia Law

Watkins was convicted of first-degree murder in Massachusetts state court in 2005 for a fatal 2003 shooting. The Supreme Judicial Court affirmed his conviction. His federal habeas petition was denied.The First Circuit affirmed the denial of relief. The state courts made an error of fact in their decisions, rejecting a “Brady” claim that a withheld a police report could have been used for the impeachment of a witness (Rudolph), finding that the report did not show the investigating officers were aware that Rudolph was a witness against Watkins. Under the Antiterrorism and Effective Death Penalty Act's deferential standard of review or applying de novo review, Watkins has not shown prejudice arising from the error or with respect to any of his other claims. There was an extensive examination of bias, and the failure to add onto any such evidence hardly would be prejudicial. Rudolph's motivation for reaching out to the police and the agreement that Rudolph later reached with the Commonwealth were discussed at trial and clearly informed Watkins and the jury that Rudolph sought an incentive in return for his cooperation and testimony. View "Watkins v. Medeiros" on Justia Law

Phillips was convicted of offenses, including felony murder, attempted first-degree murder, aggravated rape, especially aggravated kidnapping, and especially aggravated burglary. The Court of Criminal Appeals modified the especially aggravated burglary conviction to aggravated burglary. Phillips sought post-conviction relief, asserting that his trial counsel was constitutionally ineffective by failing to seek suppression of various statements he made to police. The Court of Criminal Appeals affirmed the denial of relief.The Tennessee Supreme Court affirmed, clarifying the petitioner’s burden to establish prejudice when he alleges counsel was constitutionally ineffective for failing to file a motion to suppress on Fourth Amendment grounds: The petitioner must prove that his Fourth Amendment claim is meritorious and that there is a reasonable probability that the verdict would have been different absent the excludable evidence. Despite the Fourth Amendment concerns brought about by the Memphis Police Department’s use of a 48-hour hold policy, there is no proof that the probable cause determination was unreasonably delayed and Phillips’s arrest was supported by probable cause. Given the proof of his guilt, Phillips has not established a reasonable probability that his verdict would have been different had his statements to the police been suppressed. View "Phillips v. State of Tennessee" on Justia Law

On July 18, 2012, Robinson beat, bound, and immolated his nine-months-pregnant girlfriend, S.H., in their apartment, killing her and their unborn child, B.H. He then placed a 9-1-1 call to report a fire. Upon extinguishing the fire, responders discovered S.H.’s partially burned body lying face down on the bedroom floor with her feet and hands bound, wrists handcuffed, mouth and eyes covered with duct tape, and mouth stuffed with cloth. A search of Robinson’s backpack revealed rolls of duct tape, pieces of crumpled duct tape, a matchbook with at least one match missing, and a receipt reflecting purchases of duct tape and a bottle of lighter fluid that day. Police found a handcuff key in Robinson’s pocket.Robinson was sentenced to death. The Arizona Supreme Court affirmed, first rejecting “Batson” challenges to the dismissal of potential minority jurors. The court upheld the jury’s “especial cruelty” and its “heinous or depraved conduct” findings. The legislature’s decision to equate feticide with infanticide also makes B.H.’s murder senseless as a matter of law. Robinson’s double-counting argument failed. Although the jury was prohibited from weighing B.H.’s age twice as it “assesse[d] aggravation and mitigation” at the penalty phase, it was permitted to “use one fact to find multiple aggravators” at the aggravation phase. The court also rejected challenges to jury instructions and statements made by the prosecutor. View "State of Arizona v Robinson" on Justia Law

Westray pleaded guilty to a 1998 murder. He received a death sentence which was later commuted to life imprisonment. In a habeas petition under 28 U.S.C. 2254, he subsequently challenged his confinement, including its duration, claiming ineffective assistance of counsel during sentencing and on remand when he moved to withdraw his guilty plea.The Seventh Circuit affirmed the denial of his claims. The ineffective assistance of trial counsel claim was presented to the Illinois trial court in Westray’s motion to withdraw his guilty plea, which was denied without comment. It is therefore presumed that the claim was adjudicated on its merits and AEDPA deference applies. Westray has not shown that but for his trial counsel’s allegedly deficient performance on remand, he would have been sentenced to a term of years. Westray cannot prove prejudice and his claim for ineffective assistance of trial counsel fails. No evidentiary hearing was required. View "Westray v. Brookhart" on Justia Law

Plaintiff was on parole when she was evicted from her apartment. She sent a letter to the parole office about her eviction and provided updated contact information, but the parole office was unable to contact her with the information provided. The parole office then suspended Plaintiff’s parole and issued a “retake warrant.” Plaintiff was arrested seven years later. At the revocation hearing, the parole office decided not to revoke Plaintiff’s parole, retroactively rescinded her parole suspension, restored her parole end date to March 2015, and released her from custody. During the two months she was detained, Plaintiff lost her home, business, and pets.   The Ninth Circuit held that the parole officer permissibly suspended plaintiff’s parole. Plaintiff’s arrest was reasonable under the Fourth Amendment because the parole office had a reasonable belief that she violated her parole. Because the Fourteenth Amendment does not require notice to a parolee before a parole suspension hearing, and because plaintiff was largely responsible for the seven-year delay in her arrest, her arrest did not violate due process. Plaintiff’s state law claims failed because the defendants had no waived immunity for false imprisonment or false arrest, and she could not establish the elements of her negligence and intentional infliction of emotional distress claims. View "ELIZABETH CORNEL V. STATE OF HAWAII" on Justia Law

The California Insurance Commissioner filed an ex parte conservation application to place the California Insurance Company (“CIC I”) in a conservatorship after CIC I’s president attempted to consummate a purchase transaction with Berkshire Hathaway without the Commissioner’s approval, and then attempted to bypass the California insurance regulatory scheme by merging CIC I with the California Insurance Company (“CIC II”), a New Mexico-domesticated shell company formed by the president. The Superior Court granted the Commissioner’s conservatorship application and appointed the Commissioner as Conservator of CIC I. Applied Underwriters, of which the president is the Chief Executive Officer, and CIC II filed separate actions in federal court asserting causes of actions under Section 1983.   The district court dismissed both actions pursuant to Federal Rule of Civil Procedure 12(b)(1). The Ninth Circuit held that because important considerations of federalism were at stake, the district court’s reliance on Younger abstention as a ground for dismissal was in error. The court held that an insurance conservatorship is not sufficiently akin to criminal prosecution to bring it within the purview of what constitutes a similar, Younger-eligible “civil enforcement proceeding.”   The court held that dismissal of Appellants’ claims was warranted on account of the prior exclusive jurisdiction rule. Further, Appellants’ interests were well represented in the conservatorship action; they had an adequate opportunity to raise constitutional challenges; they failed to sufficiently allege that the conservatorship action was brought in bad faith; they failed to demonstrate irreparable injury arising from extraordinary circumstances which might justify an exception to the prior exclusive jurisdiction rule. View "APPLIED UNDERWRITERS, INC. V. RICARDO LARA" on Justia Law

Plaintiffs, filed suit against Arkansas, patrolman in his individual capacity.  Plaintiffs pleaded claims under 42 U.S.C. Section 1983, alleging that the patrolman had violated their constitutional right to be free from unreasonable searches and seizures. Plaintiffs also sued the Wynne police chief, and the mayor, in their individual capacities, for failing to supervise the patrolman.   Defendants moved for summary judgment based on qualified immunity. The district court denied the motion. The Eighth Circuit reversed. The court held that Defendants are entitled to qualified immunity unless their actions violated a constitutional right that was clearly established. The court concluded that Plaintiff has not set forth evidence showing that the patrolman is responsible for the alleged Fourth Amendment violations.   Further, Plaintiffs allege that the Police Chief and Mayor are liable for the patrolman’s alleged unconstitutional acts because they had received notice of his behavior and failed to stop it. A supervising officer may be liable for the actions of his subordinates when “he (1) had ‘notice of a pattern of unconstitutional acts committed by subordinates’; (2) was deliberately indifferent to or tacitly authorized those acts; and (3) failed to take ‘sufficient remedial action’; (4) proximately causing injury to” the plaintiffs. Here, no evidence in the record supports a finding that either the Chief or Mayor subjectively knew of and deliberately disregarded a substantial risk of unconstitutional harms posed by the patrolman. View "Dana Harrison v. Brodie Faughn" on Justia Law

A father going through a contentious divorce was accused by his young daughter of sexual abuse. A Department of Human Services social worker observed the forensic interview, believed it was credible, obtained additional information primarily from the mother, and obtained an ex parte court order requiring the father to leave the family home. An ensuing adversary proceeding determined that the allegation was unfounded and that the mother had “wanted [the father] out of the house.” The DHS finding was set aside and, eventually, the father obtained physical care of the children. In the father's subsequent suit, the district court granted the defendants summary judgment.The Iowa Supreme Court affirmed. The claim of intentional interference with the parent-child relationship fails because that claim applies to extralegal actions— such as absconding with a child—not to judicially-approved acts. The claim for intentional infliction of emotional distress fails because the conduct here did not reach the level of an “outrage” necessary to sustain such a claim. The unreasonable search and seizure claim cannot succeed because there was no showing that the DHS social worker falsified the affidavit she submitted to the court or that the removal order would not have been granted without her questioned statements. The substantive due process claim fails because DHS’s conduct does not “shock the conscience.” A procedural due process claim cannot prevail because the father was provided with adequate process, which ultimately cleared his name. View "Lennette v. State of Iowa" on Justia Law

In 2005, Sandoval was convicted of two counts of first-degree murder and two counts of attempted murder. He was sentenced to serve concurrent terms of life imprisonment without the possibility of parole for the murder convictions and 25 years’ imprisonment for the attempted murder convictions. Sandoval unsuccessfully challenged his convictions on direct appeal and in three different applications for postconviction relief.The Iowa Supreme Court affirmed the dismissal of Sandoval’s fourth application for postconviction relief, which the district court held was barred by the three-year statute of limitations of Iowa Code section 822.3. Sandoval argued that because he was only 19 at the time he murdered two people, his mandatory life sentences without the possibility of parole violated the federal and state constitutional prohibitions against “cruel and unusual punishment.” U.S. Const. amend. VIII; Iowa Const. art. I. The court disagreed. Sandoval’s mandatory sentences of lifetime incarceration without the possibility of parole for committing these offenses are not categorically prohibited by either the Federal Constitution or the state constitution. View "Sandoval v. State of Iowa" on Justia Law