Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant of assault with a weapon, a felony, and misdemeanor possession of marijuana and drug paraphernalia and sentencing him to a nine-year prison term, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the State's peremptory strike of the only non-white member of the jury venire was not plain error under the three-prong equal protection analysis set forth by Batson v. Kentucky, 476 U.S. 79 (1986); (2) Defendant failed to establish plain error as to his arguments regarding various unpreserved assertions of error regarding the prosecutor’s closing argument and rebuttal comments; and (3) defense counsel's withdrawal of the Batson challenge and failure to object to certain statements by the prosecutor did not constitute ineffective assistance of counsel. View "State v. Miller" on Justia Law

The First Circuit reversed the judgment of the district court denying Defendants' motion for entry of an automatic stay under 11 U.S.C. 922, incorporated into Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), 48 U.S.C. 2101-2241, through 48 U.S.C. 2161(a), holding that Defendants were entitled to an automatic stay.Plaintiffs, who owned an operated the Integrand Assurance Company, sued Defendants, Puerto Rico government officials whose defense was assumed by the Commonwealth of Puerto Rico pursuant to the Commonwealth's legal representation and indemnification statute, alleging, among other claims, that the government officials violated their First Amendment rights, the Equal Protection Clause, and the Due Process Clause. Defendants, who were granted legal representation under Law 9, filed a notice of automatic stay. The district court denied the motion, concluding that PROMESA did not stay the litigation. The First Circuit reversed, holding that the automatic stay provision in Title III of PROMESA applied to this action. View "Victor J. Salgado & Associates v. Cestero-Lopategui" on Justia Law

In 1979-1980, Lesko went on a multi-day “Kill for Thrill” spree with his friend, Travaglia, ending the lives of four individuals in Western Pennsylvania. For the killing of a 21-year-old police officer, Lesko was convicted of first-degree murder and sentenced to death. Lesko proceeded through many levels of the Pennsylvania state courts and two rounds of federal habeas proceedings. The Third Circuit affirmed the denial of his latest petition under 28 U.S.C. 2254 petition, which challenged both his 1981 guilt-phase trial and his 1995 resentencing. The court rejected claims that the prosecution violated Lesko’s Brady rights by suppressing an agreement between a prosecution witness who was found in possession of Lesko’s gun (Montgomery) and the prosecution; a January 1980 police report; and information from the juvenile file of another prosecution witness, Rutherford. Lesko’s counsel did not perform ineffectively by violating his right to testify; Lesko was not prejudiced by any ineffectiveness in failing to properly investigate and present mitigating evidence at resentencing. View "Lesko v. Secretary Pennsylvania Department of Corrections" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of felony possession of a deadly weapon with unlawful intent, holding that there was no error in the proceedings below.Defendant pleaded nolo contendre to one count of felony possession of a deadly weapon with unlawful intent. Defendant subsequently filed a motion to withdraw his no contest plea pursuant to Wyo. R. Crim. P. 32(d), which the district court denied. After Defendant was sentenced he filed a motion to withdraw his plea pursuant to Wyo. R. App. P. 21. The district court denied the motion. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant's Rule 21 motion to withdraw his plea on grounds of ineffective assistance of counsel; and (2) the district court correctly exercised its discretion in denying Defendant's Rule 32(d) motion because Defendant did not present a fair and just reason for withdrawal. View "Delgado v. State" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for certain domestic violence incidents, including possession of a firearm by a prohibited person, holding that Defendant was not entitled to relief on his allegations of error.After a jury convicted him of six offenses Defendant appealed, raising several allegations of error. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in denying Defendant's request for sanctions for the State’s alleged discovery violations; (2) the trial court did not commit obvious error by admitting testimony of a police officer, including certain statements under Me. R. Evid. 801(d)(1)(B); (3) the trial court did not abuse its discretion in admitting an unauthenticated letter that Defendant claimed was written on behalf of the victim; (4) the court did not err when it denied Defendant's motion to dismiss because of the makeup of the jury venire; and (5) there was sufficient evidence for the jury to have rationally found that every element of each count Defendant was convicted of was proved beyond a reasonable doubt. View "State v. Thomas" on Justia Law

Ford, a Haitian national, became involved in Haitian national politics by joining PPD in 2012; he believed the ruling political party, PHTK, was corrupt and involved in human rights abuses. Ford received anonymous threatening telephone calls; in 2014, armed men encircled Ford’s home, shot into it, and burned it down. Ford reported the attack to Haitian authorities and fled Haiti. The United States began removal proceedings.Ford hired an attorney, who submitted a Form I-589 application for asylum, withholding of removal, and relief under the Convention Against Torture. Ford and the attorney subsequently had little contact. Ford stated the attorney “never prepared me for my final hearing.” The attorney provided scant documentary evidence to support Ford’s application and did not submit any documents about the PPD. The IJ denied relief, finding that Ford was credible but had “submitted no objective evidence” to help meet his burden in proving that he was harassed or persecuted on account of his political opinion or that Ford’s fear of persecution upon his return to Haiti was reasonable. Ford retained new counsel. The BIA affirmed and denied a motion to reopen Ford’s case based on ineffective assistance.The Third Circuit vacated. Ford presents a meritorious ineffective-assistance claim; his lawyer failed to present important and easily available evidence going to the heart of Ford’s claims. View "Saint Ford v. Attorney General United States" on Justia Law

A fire consumed Jones’s house in 2013. York, a county sheriff’s investigator, initially blamed an electrical malfunction. When he learned that Jones’s friend, Onopa, claimed to have a recording of Jones admitting to arson, he reopened the investigation. York interviewed several witnesses, analyzed Jones’s telephone records, and secured Onopa’s recording, then referred the matter to the district attorney, After her conviction, Jones obtained new counsel and argued that her trial counsel was ineffective for failing to move to suppress Onopa’s recording as created for the purpose of extortion. Before the court ruled on the matter, the district attorney dropped all charges against Jones. Jones then sued York and Adams County under 42 U.S.C. 1983. She contended that York violated her due process rights by withholding exculpatory evidence, fabricating inculpatory evidence, testifying falsely at trial, and prosecuting her without probable cause.The district court granted the defendants summary judgment to the defendants. The Seventh Circuit affirmed. No reasonable jury could find for Jones on any of her claims. Jones’s cell phone records were presented and discussed by both sides at trial. The jury heard testimony from York, Jones, and Onopa. Questioning by both sides exposed the discrepancies in each witness’s version of events. Jones failed to show a genuine dispute of fact as to whether York fabricated evidence. View "Jones v. York" on Justia Law

During his 2018 Senate reelection campaign, Cruz loaned his campaign committee $260,000. Section 304 of the 2002 Bipartisan Campaign Reform Act restricts the use of post-election campaign contributions, 52 U.S.C. 30116(j). Federal Election Commission regulations establish that a campaign may repay up to $250,000 in candidate loans using contributions made at any time and may use pre-election contributions to repay any portion exceeding $250,000 only within 20 days of the election; after that deadline, any portion above $250,000 is treated as a campaign contribution, precluding repayment. The Committee began repaying Cruz’s loans after the 20-day post-election window, leaving $10,000 unpaid. Cruz and the Committee challenged Section 304.The Supreme Court affirmed summary judgment for the plaintiffs. The plaintiffs had standing. An injury resulting from the application or threatened application of an unlawful enactment remains fairly traceable to such application, even if the injury was "willingly incurred." The present inability of the Committee to repay and Cruz to recover the final $10,000 is traceable to Section 304.The loan-repayment limitation abridges First Amendment rights by burdening candidates who wish to make expenditures on behalf of their own candidacy through personal loans. It increases the risk that such loans will not be repaid in full, which deters candidates from making loans. Debt is a ubiquitous tool for financing electoral campaigns, especially for new candidates and challengers. Section 304 raises a barrier to entry. The only permissible ground for restricting political speech is the prevention of “quid pro quo” corruption or its appearance. The government failed to identify a single case of quid pro quo corruption in this context, even though most states do not impose any similar limitations. View "Federal Election Commission v. Cruz" on Justia Law

The Supreme Court affirmed the judgment of the habeas court granting Petitioner's petition for writ of habeas corpus after determining that Petitioner had suffered prejudice as a result of the ineffective assistance of his trial counsel, holding that there was no error.In granting habeas relief, the habeas court determined that Petitioner's trial counsel failed to provide Petitioner with professional advise and assistance during pretrial plea negotiations and that Petitioner would have accepted the trial court's pretrial plea offer but for the ineffective assistance of Petitioner's trial counsel. The Supreme Court affirmed, holding that the habeas court did not err in concluding that Petitioner had fulfilled his burden of establishing prejudice. View "Barlow v. Commissioner of Correction" on Justia Law

Officers of the Prentiss Police Department arrested Plaintiff for aggravated assault after he and others told the officers that Plaintiff had shot the victim. Plaintiff sued the officers and the City of Prentiss under 42 U.S.C. Section 1983 for arresting him without probable cause. He argued that the officers lacked probable cause because he told them that he shot the victim in self-defense. The district court granted summary judgment on all claims and awarded fees to the defendants.   On appeal, Plaintiff argued, first, that the Officer and Chief arrested him without probable cause and that they are not entitled to qualified immunity. Second, the Chief intentionally or recklessly omitted material statements in the warrant affidavit, resulting in a warrant lacking probable cause. Third, the City of Prentiss is liable under Monell. Fourth, he established a material fact issue on his state-law malicious-prosecution claim. Finally, Defendants are not entitled to attorneys’ fees.   The Fifth Circuit affirmed the district court’s summary judgment order and award of fees to Defendants. The court reasoned it is not enough to invoke the general principle that the Fourth Amendment prohibits a warrantless arrest without probable cause. Therefore, the Officer and Chief would be entitled to qualified immunity even if they lacked probable cause for the initial warrantless arrest. Further, the court concluded that Plaintiff cannot show want of probable cause therefore, his malicious-prosecution claim cannot succeed. Finally, Plainitff has not shown that the district court abused its discretion in granting attorneys’ fees. View "Loftin v. City of Prentiss, MS" on Justia Law