Justia Civil Rights Opinion Summaries

Gaines served as the “muscle” in a drug house. Thompson came to the house to buy drugs. Williams, a visitor, told Thompson that the house was “closed,” denied him entry, and told him to leave. Thompson kept knocking and asking to come in. Eventually, Gaines walked outside and an argument ensued. Williams joined them. Gaines ultimately stabbed Thompson multiple times. Williams pulled Gaines off of Thompson. Stab wounds resulted in hemorrhaging that caused Thompson’s death. Gaines was convicted in Pennsylvania state court of first-degree murder in Pennsylvania,Gaines sought habeas relief, 28 U.S.C. 2254. The district court granted his petition, holding that Gaines’s trial counsel was ineffective for not objecting to the omission of a jury instruction that no adverse inference could be drawn from Gaines’s election not to testify in his own defense. The Third Circuit reversed. Gaines’s trial counsel made a reasonable tactical choice when he did not object. Counsel testified he was aware that the court failed to give the requested no-adverse-inference instruction, but that he decided not to object because he “was concerned that throwing [the instruction] in at the end" may have drawn undue attention to the fact that Gaines did not testify. He testified that he was satisfied with the charge as it stood because it placed the burden of proof squarely on the Commonwealth and exhaustively detailed the law of self-defense. View "zGaines v. Superintendent Benner Township" on Justia Law

Burnett was charged with failure to appear for a work-detail program. At Burnett’s arraignment hearing, his behavior was so erratic that the court held Burnett in contempt and sentenced him to jail. A mental health representative advised Sergeant Griffith that Burnett should be placed on suicide watch. While being escorted to a cell, Burnett attempted to break away. Griffith pulled Burnett backward. Burnett continued his efforts. Griffith took him down to the floor with significant force, then knelt over Burnett in an effort to control him. Burnett continued moving. Officer Tessar joined Griffith. Burnett claims that he temporarily lost consciousness. Griffith called for assistance when he noticed that Burnett had a laceration on his head and was bleeding. Other officers and a nurse arrived. Burnett was taken to a hospital, where he received three stitches, then was discharged in good condition. Burnett claims that he suffers from PTSD, migraines, back pain, and personality changes.The Sixth Circuit affirmed the dismissal of his 42 U.S.C. 1983 claims. The law at the time that Griffith acted did not provide him with fair warning that his actions would violate Burnett’s Eighth Amendment right to be free from the use of excessive force; his actions were not so egregious as to obviate the requirement of identifying precedent that places the statutory or constitutional question beyond debate. View "Burnett v. Griffith" on Justia Law

The Supreme Court affirmed Defendant's convictions for, among other crimes, two counts of aggravated murder with four death-penalty specifications attached to each count and Defendant's sentence of death, holding that there was no reversible error.Specifically, the Supreme Court held (1) Defendant's argument that the Ohio Constitution limits the right to self-representation was not well taken; (2) Defendant failed to show plain error as to his argument that his standby counsel interfered with his trial preparation and strategy; (3) the evidence was sufficient to support the convictions; (4) there was no abuse of discretion in jury selection; (5) the court did not admit inadmissible victim-impact testimony from witnesses during the trial phase or commit other reversible evidentiary error; (6) there was no prosecutorial misconduct or ineffective assistance of counsel; and (7) Defendant's remaining assignments of error were unavailing. View "State v. McAlpin" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of felony-murder in the first degree and the denial of his motion for a new trial, holding that there was no error that would necessitate a new trial, and there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or to reduce the conviction to a lesser degree of guilt.On appeal, Defendant argued, among other things, that his felony-murder conviction must be reversed because his accomplice was killed during a struggle with the intended robbery victim, and therefore, the theory of felony-murder was inapplicable. The Supreme Judicial Court affirmed, holding (1) the felony-murder rule was applicable; (2) the evidence was sufficient to support Defendant's convictions; and (3) Defendant's remaining assignments of error were without merit. View "Commonwealth v. Duke" on Justia Law

Ostrowski worked for the Lake County Sheriff’s Department before a workplace injury left him permanently disabled. He now receives a monthly pension payment from the County. Lake County’s disability pension plan does not provide cost-of-living increases, while its pension plan for non-disabled retirees does. Ostrowski filed suit, arguing that the difference between the plans violated the Equal Protection Clause, Title I of the Americans with Disabilities Act, 42 U.S.C. 12112, and the Rehabilitation Act, 29 U.S.C. 794. The district court held that Ostrowski’s suit was barred by a 2017 waiver that he signed while settling a “reasonable accommodation” claim against Lake County. The Seventh Circuit affirmed in part. Ostrowski’s claims were not barred by the waiver, but failed on the merits; the court noted a general exclusion in the agreement for matters affecting Ostrowski’s pension. Retired and other former workers are not protected by Title I of the ADA and Ostrowski forfeited his arguments with respect to the Rehabilitation Act. Ostrowski’s Equal Protection claim qualified only for rational basis review. Lake County has a legitimate interest in providing pension plans that meet the differing needs of distinct groups; the cost-of-living adjustment is one of several relevant differences in the plans. The court reversed an award of fees and costs. View "Ostrowski v. Lake County, Indiana" on Justia Law

Berkman killed his drug supplier. An Indiana jury acquitted Berkman on a first-degree murder charge, but could not reach a verdict related to felony murder. At a second trial, a key prosecution witness, Timmerman, was declared unavailable due to illness; her testimony from the first trial was read into the record. Berkman appealed his subsequent conviction, challenging the admission of Timmerman’s testimony. The Court of Appeals of Indiana determined that the trial court did not abuse its discretion in admitting the evidence given that Timmerman was unavailable and that Berkman had had an opportunity to cross-examine her at the first trial. The Indiana Supreme Court denied transfer.Berkman filed a pro se federal habeas petition in which he maintained that the introduction of Timmerman’s testimony violated his Sixth Amendment right to confront witnesses. The Seventh Circuit upheld the denial of relief. The Court of Appeals of Indiana did not unreasonably apply the Supreme Court’s “Crawford” decision. Timmerman initially was unavailable because she was hospitalized following a sudden illness. The trial court postponed the trial for several days; there is no Supreme Court precedent that required the court to reevaluate Timmerman’s condition after the early-lunch recess to determine whether her condition had improved so that she was able to testify. View "Berkman v. Vanihel" on Justia Law

Plaintiffs challenged the bans on long guns and semiautomatic centerfire rifles under the Second Amendment. The district court declined to issue a preliminary injunction. The Ninth Circuit held the district court did not abuse its discretion in declining to enjoin the requirement that young adults obtain a hunting license to purchase a long gun. However, the court found that the district court erred in not enjoining an almost total ban on semiautomatic centerfire rifles. The court found that the Second Amendment protects the right of young adults to keep and bear arms, which includes the right to purchase them.   The court held that the district court’s reasoning that the laws did not burden Second Amendment rights was a legal error. The court further held that the district court properly applied intermediate scrutiny to the long-gun hunting license regulation and did not abuse its discretion in finding it likely to survive. However, the district court erred by applying intermediate scrutiny, rather than strict scrutiny, to the semiautomatic centerfire rifle ban. And even under intermediate scrutiny, this ban likely violates the Second Amendment because it fails the “reasonable fit” test. Finally, the court held that the district court abused its discretion in finding that Plaintiffs would not likely be irreparably harmed. View "MATTHEW JONES V. ROB BONTA" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus, holding that Appellant did not show that the parole-revocation proceedings violated his constitutional right to due process.Appellant was convicted of aggravated murder and aggravated robbery and was later released on parole. Appellant was subsequently charged with violating the terms of his parole. After a revocation hearing, the parole board approved the hearing officer's recommendation that Appellant be ordered to serve an additional thirty-six months in prison before again becoming eligible for parole. The parole board approved the recommendation. Appellant filed an action for a writ of mandamus alleging that he was denied the effective assistance of counsel and that reversible error occurred during the revocation hearing. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant failed to show that the parole revocation proceedings violated his constitutional right to due process. View "State ex rel. Mango v. Ohio Department of Rehabilitation & Correction" on Justia Law

Defendants, Des Moines Police Department officers, lacking probable cause, took relatives of a stabbing victim to the station and held them for over three hours during which time the victim died. The district court denied qualified immunity, ruling for the family on their claims of illegal seizure and false arrest.   The Eighth Circuit affirmed the district court’s denial of qualified immunity. The court held both the duration and the nature of the seizure at issue exceeded the bounds of the Constitution.   The court reasoned that officers are entitled to qualified immunity unless (1) the evidence, viewed in the light most favorable to the plaintiffs, establishes a violation of a constitutional or statutory right, and (2) the right was clearly established at the time of the violation, such that a reasonable official would have known that his actions were unlawful.  Here, the officers seized the family against their will and without probable cause. There was no “reasonable ground” for the officers’ action.   The court concluded that there was no minimally-intrusive Terry stop and the detention was the most intrusive means of questioning survivors after a violent crime. Further, officers of the Des Moines Police Department were on notice that they could not detain someone for questioning against their will, even in a homicide investigation, absent probable cause.  The same evidence establishes the officers’ violation of sec. 1983 and the Fourth Amendment establishes a violation of the Iowa Constitution. View "Crysteal Davis v. Trevor Spear" on Justia Law

In 2016, voters elected Kent to the Ohio House of Representatives; she became a member of the House Democratic Caucus. In 2018, she distributed a press release that accused the Columbus Chief of Police of wrongdoing; another press release accused the Department of failing to take child-abuse reports seriously. She attached a letter from the Ohio Legislative Black Caucus to the mayor. Kent submitted the documents to the Caucus for public distribution. Strahorn, then the Minority Leader, prohibited the communications team from posting the press release online and blocked any publication of the release because the attached letter included unauthorized signatures. Strahorn publicly stated that he would not “tolerate a member of the caucus using staff and tax-payer funded resources to fake, forge or fabricate any claim, request or document to further their own political interest or personal vendetta.” The Caucus voted to remove Kent, who lost access to policy aides, communications professionals, lawyers, and administrative staff. Kent was reelected. In 2019, Kent was blocked from attending a Democratic Caucus meeting. Kent did not run for reelection in 2020.Kent filed a 42 U.S.C. 1983 claim, alleging that she suffered retaliation for speech protected under the First and Fourteenth Amendments. The Sixth Circuit affirmed the dismissal of her suit, citing legislative immunity. The Caucus is inextricably bound up in the legislative process. “Whatever the lawmakers’ motives, principles of immunity fence [courts] out of the legislative sphere.” View "Kent v. Ohio House of Representatives" on Justia Law