Justia Civil Rights Opinion Summaries

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

Plaintiff led police on a high-speed chase through a residential neighborhood. Once Plaintiff exited his vehicle, Defendant sheriff's deputy tased Plaintiff. Plaintiff sued the deputy, claiming he violated Defendant's Fourth Amendment Rights. The District Court denied the deputy's claim of qualified immunity, finding there were material factual disputes as to whether a reasonable officer would have viewed Plaintiff as an immediate threat; whether Plaintiff's apparent surrender was a ploy to evade arrest; and whether Plaintiff was tased once or twice.The Fifth Circuit reversed. After considering the threat posed by Plaintiff in fleeing law enforcement as well as the force used by the deputy, the court determined that the deputy did not violate Plaintiff's clearly established constitutional rights under the Fourth Amendment. Thus, Plaintiff was unable to overcome the bar of qualified immunity. View "Salazar v. Molina" on Justia Law

Marsalis is a nursing-school dropout but on dating websites, he was “Dr. Jeff,” a high-flying physician at the University of Pennsylvania and also a NASA astronaut. When an unsuspecting woman fell for Marsalis’s ruse, he drugged her drink, then offered to let her recover at his apartment. As the woman blacked out, he sexually assaulted her. In total, 10 women accused Marsalis of rape, each telling a version of that same story. A jury acquitted him of rape, convicting him only of two sexual assaults. The judge found that he was a sexually violent predator and sentenced him to the maximum: up to 21 years in prison. On state habeas review, Marsalis argued that his trial counsel was ineffective for failing to present an alibi defense and investigate a victim’s medical condition. The court dismissed his petition, and the Superior Court affirmed.Marsalis filed this federal habeas petition, arguing that trial counsel should have objected to a doctor’s expert testimony. The district court rejected the ineffective-counsel claim because Marsalis had not raised it during state habeas. The Third Circuit affirmed. Marsalis’s federal habeas challenge was untimely and a jury would have convicted him even if his lawyer had been adequate. View "Marsalis v. Pennsylvania Department of Corrections" on Justia Law

In response to the COVID-19 pandemic, Minnesota Governor Tim Walz declared a state of “peacetime emergency” and began issuing executive orders (EOs) intended to combat the spread of the virus. The EOs limited which types of businesses could continue operations and, later, specified the capacities at which those businesses could operate. Plaintiffs, three Minnesota businesses and their respective owners, suffered financial losses during the COVID-19 pandemic while these EOs were in effect. Plaintiffs brought an Equal Protection Clause claim against Governor Walz and Minnesota’s Attorney General, in their official capacities and a Takings Clause claim against Governor Walz in his individual capacity, which the district court dismissed.   The Eighth Circuit affirmed the dismissal. The court found that in 2020, the law was not clearly established such that Governor Walz would have understood that his issuance of the challenged EOs violated Plaintiffs’ constitutional right to just compensation for a government taking. The court explained that Plaintiffs have not offered anything that supports their hypothesis that Governor Walz will, first, declare a second peacetime emergency and, then, will issue additional EOs—specifically, EOs like 20-74 that, in their view, treat them differently than other, similarly situated businesses and impede them from conducting their businesses as they wish. The court further wrote that it need not parse through whether or not a taking occurred, however, because even assuming that a taking did occur, whatever its type, Plaintiffs have offered nothing to support their contention that, in 2020, the law was clearly established such that Governor Walz would have understood that his EOs constituted a taking. View "Glow In One Mini Golf, LLC v. Tim Walz" on Justia Law

Plaintiff sued Defendant, a law enforcement officer employed by the United States Immigration and Customs Enforcement agency (ICE). Martinez claims that Sasse violated her rights under the Fourth Amendment by effecting a seizure through the use of excessive force. Sasse moved for judgment on the pleadings and argued that she was entitled to qualified immunity. denied the motion, reasoning that Martinez’s allegations stated a claim for the violation of a clearly established right.   The Eighth Circuit reversed and remanded the case with directions to dismiss the Fourth Amendment claim against Defendant. The court concluded that Plaintiff has not adequately pleaded that Defendant violated a clearly established right, because it was not clearly established as of June 2018 that Defendant’s alleged push was a seizure under the Fourth Amendment. Accordingly, Defendant is entitled to qualified immunity. The court explained that although the claim here alleges the use of excessive force, the parties dispute the threshold question of whether Defendant seized Plaintiff at all within the meaning of the Fourth Amendment. Plaintiff argues that Defendant effected a seizure when she pushed Plaintiff to the ground before locking the doors to the ICE facility. Defendant maintains, however, that when an officer’s use of force is designed only to repel a person from entering a facility, there is no seizure. On that view, Plaintiff may have a tort claim against Defendant for assault or battery if the officer used unjustified force, but Defendant did not violate the Fourth Amendment. View "Andrea Martinez v. Ronnet Sasse" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that there was no error.Defendant was convicted of three counts of first-degree sexual assault, one count of kidnapping, and one count of aggravated assault and battery. The Supreme Court affirmed on direct appeal. Defendant later filed his motion to correct an illegal sentence, asserting that his sentence violated constitutional prohibitions against double jeopardy. The district court denied relief, determining that Defendant's claims were barred by res judicata and failed on the merits. The Supreme Court affirmed, holding that Defendant's motion to correct an illegal sentence was barred by res judicata. View "Harrell v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained after law enforcement entered her home without a warrant or consent, holding that the district court erred.Defendant entered a conditional plea of guilty to felony driving under the influence. On appeal, Defendant challenged the district court's denial of her motion to suppress, arguing that the record did not support a finding that her husband consented to a law enforcement officer's entry into their home. The Supreme Court reversed and remanded the case, holding (1) the district court erred in concluding that the officer had implied consent to enter the home; and (2) therefore, the officer violated the Fourth Amendment to the United States Constitution. View "Hawken v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's Rule 37 petition alleging ineffective assistance of counsel during his criminal trial, holding that there was no error or abuse of discretion.Defendant was convicted of and sentenced to death for capital murder. The Supreme Court affirmed. Defendant later filed a petition for postconviction relief arguing that his trial counsel were constitutionally ineffective for multiple reasons. The circuit court denied the petition. The Supreme Court affirmed, holding that Defendant's allegations of error were unavailing. View "Holland v. State" on Justia Law

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