Justia Civil Rights Opinion Summaries

Plaintiffs filed a 42 U.S.C. Section 1983 action shortly after her son’s death, alleging that officers violated her son’s constitutional rights by failing to provide him with medical treatment while he was dying in a jail cell. The officers moved for summary judgment based on qualified immunity. The district court denied the officers’ motion. It found genuine disputes of material fact surrounding Plaintiff’s claims that the officers were deliberately indifferent to the man’s serious medical needs. And it concluded that the law was clearly established at the time of the alleged violation.   The Fifth Circuit affirmed the district court’s ruling and found that (1) the fact disputes identified by the district court are material to Plaintiff’s deliberate indifference claims, and (2) the court’s decision in Easter clearly established the man’s rights before the officers allegedly violated them.The court explained that in reviewing qualified immunity it looks to: (1) whether the defendant violated the plaintiffs’ constitutional or statutory rights; and (2) whether those rights were clearly established at the time of the violation. The court reasoned those it lacks jurisdiction to review the genuineness argument because the officers’ arguments do not address why the fact disputes the district court did find cannot affect the outcome of Plaintiff’s lawsuit—the materiality inquiry. Further, in reviewing Easter v. Powell, 467 F.3d 459 (5th Cir. 2006), the court held that a reasonable jury could find that the officers each refused to treat the man, ignored his cries for help, and overall evinced a wanton disregard for his serious medical needs. View "Sims v. Griffin" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for four counts of murder in the first degree on the theory of felony-murder and the order denying his motion for a new trial and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Judicial Court held (1) the judge did not abuse his discretion in denying Defendant's motion for a new trial; (2) Defendant's trial counsel did not provide ineffective assistance of counsel; (3) Defendant's argument that exculpatory evidence pointed to another suspect was unavailing; (4) the prosecutor did not commit misconduct during closing arguments; and (5) the judge did not abuse his discretion in declining to strike a juror. View "Commonwealth v. Moore" on Justia Law

The Supreme Court affirmed Defendant's convictions for partner or family members assault (PFMA), unauthorized use of a motor vehicle, and two counts of tampering with witnesses or informants but reversed the district court's imposition of various fees and costs on Defendant, holding that remand was required for an analysis of Defendant's ability to pay before imposing costs and fees.Specifically, the Supreme Court held (1) the admission of certain hearsay statements was not harmless error; (2) Defendant's right to a fair trial by an impartial jury was not violated; (3) Defendant was not entitled to relief on his argument that his right to confrontation was violated by the repeated emphasis on recorded jail phone calls; (4) the record was insufficient to review Defendant's claim of ineffective assistance of trial counsel; and (5) the district court erred in imposing jury and other costs on Defendant without first undertaking an ability to pay inquiry. View "State v. Oliver" on Justia Law

The First Circuit reversed the decision of the district court that the prosecutor in the underlying Rhode Island case transgressed the Batson rule in the course of jury selection but that Petitioner was not entitled to habeas corpus relief, holding that the decision of the Rhode Island Supreme Court could not withstand habeas review.Petitioner, a Rhode Island state prisoner and an African-American man who was convicted of murder and other crimes, claimed in his petition for writ of habeas corpus that the prosecutor violated Batson during jury selection. The federal district court concluded that Petitioner's rights under Batson were violated but that the Rhode Island Supreme Court did not abuse its discretion in finding sufficient race-neutral reasons for a peremptory challenge against the juror in question. The First Circuit reversed, holding (1) the prosecutor's explanation for his peremptory strike was not race-neutral on its face and thus violated Batson; and (2) the Rhode Island Supreme Court's decision rested on either an unreasonable application of clearly established federal law, an unreasonable determination of the facts, or both. View "Porter v. Coyne-Fague" on Justia Law

Kansas City Officer (“Officer”) shot and killed the victim during a foot chase. Family members of the victim filed suit and the district court concluded that the Officer was entitled to both qualified and official immunity. In addition to contesting the grant of summary judgment on appeal, Plaintiffs argued they should receive a trial on their claims against the Kansas City Board of Police Commissioners and the other municipal officials named in their complaint.   In evaluating the family’s excessive-force claim against the Officer, the Eighth Circuit affirmed the district court’s decision. The court explained that the key issue requires answering whether the officer’s actions violated a constitutional right and then whether the right was clearly established. The court reasoned that the Supreme Court has explained that “the focus” of the clearly-established-right inquiry “is on whether the officer had fair notice that [his] conduct was unlawful.” Kisela v. Hughes, 138 S. Ct. 1148 (2018). Here, “judged against the backdrop of the law at the time of the conduct,” a reasonable officer would not have had “fair notice” that shooting the victim under these circumstances violated the Fourth Amendment.     Additionally, to prevail in this case under Kisela, the family would need to establish “the right’s contours were sufficiently definite that any reasonable official in the defendant’s shoes would have understood that he was violating it.” Here, the family failed to show that the Officer acted in bad faith or with malice. Finally, there is not enough evidence to find that the municipal defendants liable under a deliberate indifference theory. View "N.S. v. Kansas City Board of Police" on Justia Law

Illinois State University charges tuition and multiple fees; the Mandatory Fee covers the cost of on-campus facilities and programs. In 2020, after the Governor declared an emergency because of COVID-19 and issued an order forbidding many in-person gatherings, ISU shifted to distance learning over a video system. ISU remitted some but not all of the Mandatory Fee, telling students that the remainder includes the expense of facilities that must be supported no matter how educational services are provided. Two students filed suit under 42 U.S.C. 1983, citing the Takings Clause and the Due Process Clause.The Seventh Circuit affirmed the dismissal of the suit. The Constitution does not ensure that states keep all of their promises, any more than it ensures that states observe all of their laws. A violation of a state law or a state contract is a violation of a state entitlement, for which the remedy lies under state law. . ISU lacked authority to violate the Governor’s orders. There was no due process violation because the students were not entitled to hearings. What the students want is substantive–a full refund. A breach of contract does not violate the Constitution. Suing ISU officials in their individual capacities makes no difference; there is no vicarious liability under section 1983. “Plaintiffs’ counsel should count themselves lucky that [those officials] did not seek sanctions for frivolous litigation. View "Thiele v. Board of Trustees of Illinois State University" on Justia Law

The Materiality Provision of the Civil Rights Act, 52 U.S.C. 10101(a)(2)(B), prohibits any “person acting under color of law [from] deny[ing] the right of any individual to vote in any election because of an error or omission … if such error or omission is not material in determining whether such voter is qualified … to vote in such election.” In Pennsylvania, an error or omission is material to a voter’s qualifications to vote if it is pertinent to either the voter’s age, citizenship, residency, or felony status or the timeliness of the ballot. The Lehigh County Board of Elections (LCBE) held an election on November 2, 2021, to fill local vacancies. LCBE set aside 257 out of approximately 22,000 mail-in or absentee ballots that lacked a handwritten date next to the voter declaration signature and ballots with the date in the wrong location on the outer envelope. LCBE convened a public hearing and voted to count the undated and misdated ballots.The Third Circuit held that private plaintiffs have a private right of action to enforce section 10101 under 42 U.S.C. 1983 and that the dating provisions contained in 25 Pa. Cons. Stat. 3146.6(a) and 3150.16 are immaterial to a voter’s qualifications and eligibility under section 10101(a)(2)(B). The court directed that the undated ballots be counted. View "Migliori v. Lehigh County Board of Elections" on Justia Law

Universal Life Church Monastery permits anyone who feels called to become ordained as a minister—over the Internet, free of charge, in a matter of minutes. Tennessee law permits only those “regular” ministers—ministers whose ordination occurred “by a considered, deliberate, and responsible act”—“to solemnize the rite of matrimony.” Tenn. Code 36-3-301(a)(1)–(2). Since 2019, the law has explicitly clarified that “[p]ersons receiving online ordinations may not solemnize the rite.”Asserting that those restrictions violate the federal and Tennessee constitutions, ULC and its members sued several Tennessee officials, seeking an injunction and declaratory judgment. The officials claimed sovereign immunity and that the plaintiffs lacked standing to sue. The district court entered a preliminary injunction against several defendants. The Sixth Circuit reversed in part. No plaintiff has standing to seek relief against Governor Lee, Attorney General Slatery, District Attorney General Helper, or County Clerks Crowell, Anderson, and Knowles. The plaintiffs have standing to sue District Attorneys General Dunaway, Pinkston, and Jones, and County Clerk Nabors. The court noted that county clerks have no discretion to inspect officiants’ credentials or to deny licenses on that basis; state law deems issuance of the licenses a ministerial duty. View "Universal Life Church Monastery Storehouse v. Nabors" on Justia Law

Adams was not tried until 2017, nearly two years after his arraignment on firearms charges. Rejecting his motions to dismiss on Speedy Trial Act grounds, the district court described “numerous continuances [and] unnecessary motions,” caused by Adams’s “obstreperous behavior.” At one point, because of Adams’s demands, the judge canceled a scheduled trial date and did not set a particular date for that future hearing or for trial, without citing 18 U.S.C. 3161(h)(7)(A), which allows district courts to pause the speedy trial clock by entering a continuance, or state that this continuance would serve the “ends of justice.” Adams also argued that motions in limine filed by the government did not qualify for the Act’s exclusion of “delay resulting from any pretrial motion” under 3161(h)(1)(D), and that his motion for discovery did not toll the clock from its filing through its official disposition.The Third Circuit affirmed his convictions, concluding those periods of delay were excluded, The district court did not plainly err in failing to instruct the jury on the “knowledge-of-status” element under “Rehaif.” The record makes clear that Adams devised his straw-purchaser scheme precisely because he knew he was a felon who could not lawfully possess firearms. View "United States v. Adams" on Justia Law

The Supreme Court affirmed the order of the superior court granting Defendant's motion to suppress the statements he made to police at the scene of an automobile collision, holding that the superior court did not abuse its discretion in granting the suppression motion.Specifically, the Supreme Court held (1) the trial justice correctly determined that Defendant was in custody when he made incriminating statements to the law enforcement officer at the scene of the arrest and therefore correctly suppressed the statements Defendant made to the officers at the time; and (2) the state's second contention on appeal was not properly before the Court. View "State v. Corcoran" on Justia Law