Justia Civil Rights Opinion Summaries

Plaintiffs alleged they were sexually abused by Tyler, a Kentucky probation and parole officer, 2017-2019, while Plaintiffs served sentences for state convictions. In 2018, one victim filed a sexual harassment complaint but Tyler’s supervisor, Hall, concealed the complaint. The state terminated Hall and charged Tyler with rape in the first degree, sodomy in the first degree, sexual abuse in the first degree, tampering with physical evidence, official misconduct in the first degree, and harassment.Plaintiffs brought their claims under 42 U.S.C. 1983 and the Thirteenth Amendment, arguing that Defendants directly violated their rights. to be free from involuntary sexual servitude guaranteed by the Thirteenth Amendment and violated Plaintiffs’ Thirteenth Amendment rights to be free from “unwanted sexual physical contact,” “unwanted intrusion upon Plaintiffs’ person(s) for the sexual gratification of Defendants’ employee,” “sexual physical assault,” and “unwanted sexual contact.” Because the section 1983 limitations period had expired, Plaintiffs amended their complaint and claimed that their action arose out of the Thirteenth Amendment exclusively, disclaimed their arguments against Governor Beshear, and asserted that jurisdiction was proper under 28 U.S.C. 1331. The Sixth Circuit affirmed the dismissal of the suit; the Thirteenth Amendment neither provides a cause of action for damages nor abrogates state sovereign immunity against private damages actions. The court rejected Plaintiffs’ argument that no state or federal law prohibits them from filing suit directly against the Commonwealth. View "Smith v. Commonwealth of Kentucky" on Justia Law

The Supreme Court held that Wisconsin's operating while intoxicated (OWI) graduated-penalty scheme is unconstitutional to the extent it counts prior revocations for refusing to submit to a warrantless blood draw as offenses for the purpose of increasing the criminal penalty.When Defendant was convicted of his sixth OWI offense the court counted as one of his six prior offenses a 1996 temporary revocation of Defendant's driving privileges for refusing to submit to a warrantless blood draw, which led to Defendant receiving a longer sentence. On appeal, Defendant argued that Wisconsin's graduated-penalty scheme for OWI offenses is unconstitutional because it threatens criminal penalties for those who exercise their Fourth Amendment right to be free from unreasonable searches. The Supreme Court agreed, holding that Wis. Stat. 343.307(1) and 346.65(2)(am) are unconstitutional to the extent that they count as offenses prior revocations resulting solely from a person's refusal to submit to a warrantless blood draw for the purpose of increasing the criminal penalty. View "State v. Forrett" on Justia Law

The First Circuit affirmed Defendant's convictions for receipt and possession of child pornography, holding that the district court did not err in denying Defendant's pre-trial motion to suppress evidence obtained pursuant to a search warrant and did not abuse its discretion in excluding certain text-message evidence as inadmissible hearsay.On appeal, Defendant argued that the district court erred in denying his motion to suppress because the affidavit filed in support of the search warrant failed sufficiently to describe ether pornographic images to be found and that the court erred in excluding from his trial the text message evidence at issue. The First Circuit affirmed, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; and (2) the district court did not err in barring the text messages from Defendant's trial. View "United States v. Chiu" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing Appellant's civil rights complaint without prejudice on the grounds that Appellant failed personally to serve any of the Nevada Department of Corrections (NDOC) parties with a copy of the summons and complaint within the service period, holding that the court was required to allow Appellant additional time to cure defects in service.Specifically, the Supreme Court held (1) Appellant alleged sufficient facts to state a claim for relief under 42 U.S.C. 1983 against Respondent based on an alleged deliberate indifference to serious medical needs; and (2) Nev. R. Civ. P. 4.2(d)(6) gave Appellant additional time to complete service on the remaining respondents. Appellant, an inmate, filed this lawsuit against various officials and employees of NDOC, alleging a violation of 42 U.S.C. 1983 based on Respondents' alleged indifference to his serious medical needs. The district court dismissed the complaint for failure to state a claim. The Supreme Court reversed, holding (1) Appellant properly pleaded a section 1983 claim against Respondent; and (2) Appellant was entitled to additional time under Rule 4.2(d)(6) to serve the state officials or employees. View "Harris v. State" on Justia Law

Thomas called 911, stating that he believed he was overdosing from cocaine. Law enforcement officers customarily secure suspected drug overdose scenes before paramedics enter. Officer Pinkerman knocked on the door, which burst open. Thomas ran into the lawn, disobeying officers’ commands. When Thomas fell, Pinkerman fell on top of him. Thomas actively resisted. Four officers handcuffed Thomas and signaled to paramedics to approach. Thomas was kicking and dropping his weight, so the officers laid him down and called for a hobble strap to prevent him from kicking paramedics. Officer Shaffner applied his knee to Thomas’s lower back/hip area. Stephens had his knees against Thomas’s shoulder. Thomas was kept in this position for approximately 90 seconds while waiting for a hobble strap. Officers noticed that his breathing slowed and rolled Thomas onto his side. Paramedics administered Narcan to increase his respiratory rate and deemed Thomas to be in stable, non-life-threatening condition; minutes later he went into cardiac arrest. Thomas arrived at the hospital in critical condition. A drug screen detected marijuana, cocaine, and opiates. Thomas died of “anoxic encephalopathy” resulting from cardiac arrest.Thomas’s estate alleged that his cardiac arrest was caused by “forcible restraint that precluded adequate breathing.” The Sixth Circuit affirmed the summary judgment rejection of the estate’s 42 U.S.C. 1983 claims. The estate cannot establish that Thomas had a clearly established right against the type of force that was used; the officers are entitled to qualified immunity. View "Wiley v. City of Columbus" on Justia Law

Plaintiff, an inmate, brings a Section 1983 suit alleging the Director of the Texas Department of Criminal Justice and unidentified prison officials were deliberately indifferent to his medical needs in violation of the Eighth Amendment. The district court requested the Texas State Attorney General’s Office provide a supplemental administrative report, known as a Martinez report, to develop the record. Upon reviewing the report, the district court dismissed Plaintiff’s claims as frivolous.   The Fifth Circuit affirmed in part and vacated in part. The court explained that in reviewing whether a district court properly dismissed a prisoner’s complaint for failure to state a claim, it applies the same standard as dismissals under Federal Rule of Civil Procedure 12(b)(6). Further to show deliberate indifference a plaintiff must demonstrate that the official was aware that an inmate faces a substantial risk of serious harm and disregarded that risk by failing to take reasonable measures to abate it. Here, Plaintiff did not mention any relationship between the allegedly unconstitutional acts and the Director or any prison policy. Without such an allegation, Plaintiff cannot state a claim against him.   Next, the court concluded that if the Martinez report conflicts with the pro se plaintiff’s allegations, the district court must accept the plaintiff’s allegations as true, not the records in the report. Here, the district court relied on the Martinez report’s medical records in the face of Plaintiff’s conflicting allegations to conclude Plaintiff’s treatment was sufficient and any delay in treatment was not due to deliberate indifference. View "Davis v. Lumpkin" on Justia Law

Over three weeks in 2002, Santiago participated in a string of armed robberies at Pennsylvania hotels. When he was arrested, Santiago was holding the distinctive firearm that he and his co-defendants used in the robberies. Convicted of three Hobbs Act counts of interference with commerce by robbery, two counts of possessing a firearm in furtherance of a crime of violence, (robbery), 18 U.S.C. 924(c), and two counts of possessing a firearm as a felon (prior state felony convictions for criminal trespass and retail theft), Santiago was sentenced to concurrent terms of 42 months' imprisonment on the three Hobbs Act and two felon-in-possession counts. Under then-applicable law, Santiago also received mandatory consecutive 60-month and 300-month terms for the 924(c) counts. The Third Circuit affirmed. The Seventh Circuit rejected Santiago’s section 2241 habeas petition in which he argued that the Supreme Court’s 2019 “Rehaif” decision, required that his convictions for possessing a firearm as a felon be set aside. Santiago cannot show he was actually innocent of those charges as required to invoke the “saving” clause in 28 U.S.C. 2255(e). In order to use section 2241 to avoid the restrictions on successive 2255 motions, he would need to show that no reasonable juror could find him guilty beyond a reasonable doubt. View "Santiago v. Streeval" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Appellant failed to demonstrate entitlement to Rule 37.1 relief.After a second jury trial, Appellant was convicted of first-degree murder and attempted first-degree murder with a firearm enhancement. The convictions and sentences were affirmed on appeal. Appellant subsequently brought his petition for postconviction relief, alleging ineffective assistance of appellate counsel and pretrial counsel. The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err by denying the petition without a hearing. View "Sirkaneo v. State" on Justia Law

The Supreme Court denied Appellant's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, for issuance of a writ of habaes corpus, and to correct an illegal sentence, holding that Appellant failed to raise cognizable grounds for coram nobis relief.Appellant was convicted of aggravated robbery and aggravated residential burglary. As grounds for a writ of error coram nobis, alleging that there was insufficient evidence to support the conviction, his counsel provided ineffective assistance, the trial court committed evidentiary error, and he was arrested illegally. The Supreme Court denied the petition, holding that Appellant did not raise cognizable grounds for coram nobis relief and that Appellant failed to proceed with due diligence in bringing his claims. View "Dobbins v. State" on Justia Law

A former faculty member appealed the district court’s judgment dismissing (A) claims against the university principally for violation of his right to due process, and for gender and national origin discrimination in violation of, respectively, Title IX of the Education Amendments of 1972 and Title VI of the Civil Rights Act of 1964; and (B) claims that documents issued by the United States Department of Education violated the Administrative Procedure Act and the  Spending Clause of the Constitution. The district court granted the university's motion for judgment on the pleadings finding that Title IX does not authorize a private right of action for discrimination in employment and that the complaint failed to state a claim for national-origin discrimination under Title VI. The court granted the United States Defendants' motion to dismiss the claims.   The Second Circuit vacated the judgment in part finding merit only in Plaintiff’s contention that Title IX allows a private right of action for a university's intentional gender-based discrimination against a faculty member. The court found that the complaint contained sufficient factual assertions to permit a plausible inference that Plaintiff was disciplined following irregular investigative procedures in circumstances permitting a plausible inference of bias on the basis of gender in violation of Title IX. Plaintiff’s Title VI claim, viewed within the same analytical framework as that applicable to his Title IX claim, lacks sufficient factual assertions to permit a plausible inference that Plaintiff was disciplined in whole or in part on the basis of his national origin in violation of Title VI. View "Vengalattore v. Cornell University" on Justia Law