Justia Civil Rights Opinion Summaries

Vacaville Officer Hill followed a car and noticed the license plate light and third brake light at the vehicle's back window appeared not to be working. Hill initiated a traffic stop. Pantoja was alone in the car. When Pantoja gave his name, Hill remembered Pantoja “had a history of violence and firearm possession, and he was at the time an investigative lead in a homicide.” There was no smell of marijuana and no contraband in plain view. Hill saw no signs that Pantoja was intoxicated. Hill ran a record check and learned Pantoja had a valid license and was not on probation or parole. Hill asked Pantoja if he could look in the vehicle for contraband. Pantoja declined. Hill then asked Pantoja to exit his car and put his hands behind his head because Hill was going to issue a citation for the lighting infractions. Pantoja did not make any furtive gestures or sudden movements. As Hill patted Pantoja’s waistband area, he found a revolver. Pantoja was arrested.The trial court granted Pantoja’s motion to suppress, explaining: “[T]he officer … didn’t have any specific or articulable facts to believe that this individual was presently armed or dangerous. The court of appeal affirmed. An officer’s knowledge of a suspect’s past arrests or convictions is inadequate to furnish reasonable suspicion as is the knowledge that a suspect is merely under investigation. View "People v. Pantoja" on Justia Law

Around 2:00 a.m., Philadelphia Police Officers Cannon and Gonzalez, patrolling a “very violent” North Philadelphia area, saw a pickup truck roll through a stop sign and fail to signal a turn. They stopped the truck. While collecting the driver's license and registration, the officers smelled alcohol. The front seat passenger was heavily intoxicated; Hurtt, from behind, attempted to calm him. Hurtt volunteered his identification. When the driver stepped out for a sobriety test, leaving the door open. Cannon got into the truck and pointed his flashlight around the vehicle. Cannon instructed the two passengers to keep their hands visible three times. They did not comply and kept putting their hands in their pockets or the front of their pants. Although he had not yet run the driver’s license or vehicle identification nor finished the sobriety test, Gonzalez put the driver in the patrol car to help clear the passengers. After Hurrt twice appeared to be reaching into a tool bucket, Cannon searched him and found a loaded handgun in his waistband. After being arrested Hurtt made several statements without any Miranda warnings. Hurtt was charged as a felon in possession of a firearm, 18 U.S.C. 922(g)(1).The Third Circuit reversed the denial of Hurtt’s motion to suppress. Cannon created a safety concern while off-mission from the purpose of the original traffic stop and thereby wrongfully prolonged Hurtt’s detention. The disputed evidence was only uncovered after the officers went off-mission. View "United States v. Hurtt" on Justia Law

In 1992, Burns, with five accomplices, approached a car in which four men were drinking and smoking. Looking for a fight, Burns and his accomplices robbed the car's occupants, then began shooting them, killing two. Blackman escaped with a minor gunshot wound. Thomas, despite having been shot several times, survived; his testimony was instrumental in the trials. Burns was convicted on two counts of felony murder, receiving a death sentence for one murder and a life sentence for the other. Seeking habeas relief, Burns claimed that he received ineffective assistance of counsel at the sentencing stage and that the Tennessee prosecutor wrongfully relied on inconsistent testimony and knowingly presented false testimony at the guilt stage. The Sixth Circuit affirmed the denial of relief. The Supreme Court has never established that a capital defendant has a constitutional right to introduce, at sentencing, residual-doubt evidence, offered to undermine the prosecution’s case, which led to the conviction. Burns’s counsel did not err by failing to pursue the introduction of residual-doubt evidence at sentencing. Burns’s sentencing counsel did a fair amount of investigation in preparation for the mitigation phase and adopted a strategy of focusing on Burns’s religious background and other signs of good character, which was not unreasonable. Burns fails to establish that the testimony was actually inconsistent or false. View "Burns v. Mays" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained from a blood draw conducted pursuant to a search warrant, holding that there was no error.Defendant moved to suppress evidence obtained from a blood draw, arguing that Wheatland County Justice of the Peace Richard Egabakken lacked jurisdiction to issue the warrant because the crimes occurred in Golden Valley County. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err when it concluded that Justice of the Peace Egebakken had jurisdiction to issue a search warrant for Defendant's blood draw in Wheatland County. View "State v. Grussing" on Justia Law

Lindke and his ex-girlfriend, Moeller, engaged in a child custody dispute. Moeller obtained a domestic personal protection order (PPO) against Lindke, alleging that Lindke beat her repeatedly, threatened her, and sent nude photos of her to her family, friends, and coworkers. Lindke violated that PPO twice. When it expired, Moeller sought a second PPO, claiming that Lindke continued to harass her online. Michigan state court judge Tomlinson granted another PPO. Moeller obtained sole custody, then sued Lindke in state court, alleging that his “continued harassment . . . on social media” violated the 2016 PPO. Judge Tomlinson found that most of Lindke’s online activity was constitutionally protected speech but that his act of “tagging” Moeller in a specific Facebook post violated the PPO.Rather than appeal that decision, Lindke sued Judge Tomlinson and Sheriff King in federal court, claiming that Michigan’s domestic PPO statute violated his First and Fourteenth Amendment rights (42 U.S.C. 1983). Lindke has previously sued a state-court judge in federal court. The Sixth Circuit affirmed the dismissal of the suit, concluding that no subject-matter jurisdiction existed in the case against Judge Tomlinson and that Lindke failed to state a claim against Sheriff King. View "Lindke v. Tomlinson" on Justia Law

Plaintiff arrived at Becker County Jail in Minnesota with a number of physical ailments, two weeks later he was taken to the hospital and subsequently diagnosed with acute myeloid leukemia. Plaintiff filed an action against Becker County Jail (“BCJ”) and its personnel, claiming deliberate indifference to his medical needs, failure to provide adequate training to corrections officers, and negligence. The district court held that Defendants were entitled to qualified immunity. Plaintiff filed an amended complaint under 42 U.S.C. Sec. 1983, alleging Defendants violated his rights under the Eighth and Fourteenth Amendments and claims under Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (1978).On appeal, the court reasoned that qualified immunity “shields government officials from liability when their conduct does not violate clearly established constitutional rights of which a reasonable person would have known.” The court found no violation of the Eighth or the Fourteenth Amendments because the undisputed facts do not provide sufficient proof that the defendants acted with deliberate indifference to Plaintiff’s medical needs nor do they show intentional denial or delay in access to medical care. The court reasoned that Plaintiff gave mixed signals as to the severity of his pain. Because medical professionals failed to grasp the seriousness of his condition, prison staff without medical training could not have been expected to do so. Further, because the individual Defendants are entitled to official immunity, Becker County is entitled to the same immunity. View "Kyle Rusness v. Becker County, Minnesota" on Justia Law

Plaintiff alleges that while he was detained at a detention center, officers subjected him to severe racial harassment, including the use of racial epithets, multiple times per day. He filed several internal grievances, but each was rejected. Plaintiff alleges the grievances were rejected because of his race. Plaintiff challenges the district court’s grant of summary judgment to Defendants. He also argues that the court should have construed his pleadings to include claims for retaliation and violations of the Minnesota Human Rights Act.Plaintiff argues that his summary judgment evidence and other evidence available in the record was sufficient to establish a genuine dispute of material fact. Plaintiff identifies three “buckets” of relevant evidence: (1) his counter-affidavits; (2) the internal grievance forms filed with the adult detention center; and (3) other non-summary judgment evidence available in the record.The court found that the evidence does not raise a genuine dispute that either officer was personally involved in racial harassment or discrimination at the detention center. Plaintiff's statement fails to identify any direct or circumstantial evidence that would demonstrate the denial was racially motivated. Further, Plaintiff failed to obtain sworn testimony or documentary evidence asserting specific facts to help prove his claim. The court held that Plaintiff’s summary judgment evidence is insufficient to establish a genuine dispute of material fact that Defendants were personally involved in racial discrimination or harassment. Thus, Plaintiff cannot demonstrate that either officer’s conduct violated his Fourteenth Amendment rights, and both are entitled to qualified immunity View "Wilbert Glover v. Matt Bostrom" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of murder, holding that the appellate court did not err.On appeal, the appellate court concluded that the trial court had not abused its discretion in joining Defendant's case with the codefendant's case and that Defendant's right to confrontation was not violated when the trial court allowed a state's firearms examiner to testify about the findings of a second firearms examiner. The Supreme Court affirmed, holding (1) the appellate court did not err in determining that the trial court's joinder of Defendant's and his codefendant's cases was proper; (2) the admission of CSLI information into evidence was not error; and (3) the appellate court did not err by not determining that Defendant's right to confrontation was not violated by the challenged testimony, but the violation was harmless beyond a reasonable doubt. View "State v. Tyus" on Justia Law

Plaintiff, a state prisoner, alleged that a corrections officer unlawfully tampered with his mail. The plaintiff moved pro se to proceed in forma pauperis (“IFP”), but the district court denied his motion upon finding he was barred under the “three strikes” provision of the Prison Litigation Reform Act (PLRA). The district court rejected the plaintiff’s contention that he was under imminent danger of serious physical injury, an exception that allows prisoners to proceed IFP notwithstanding the three-strikes rule.At issues on appeal are (1) whether the district court properly attributed three strikes to the plaintiff; and (2) must an allegation of imminent danger relate to a prisoner’s underlying claim to get around the PLRA’s three-strikes rule?The Ninth Circuit held a prior lawsuit constitutes a strike when it “was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted.” The court found that the district court properly assessed three strikes based on the plaintiff's prior cases.Next, the Ninth Circuit agreed with the district court that the plaintiff is not entitled IFP status regardless of whether a nexus exists, finding that Section 1915(g) contains a nexus requirement. The court affirmed the district court’s ruling because the plaintiff both accumulated three strikes and failed to establish a sufficient nexus. View "EDWARD RAY, JR. V. E. LARA" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of marijuana, aggravated fleeing or attempting to elude, reckless endangering, and interference with a peace officer, holding that the district court did not err in denying Defendant's motion to suppress.Defendant pleaded guilty to the offenses, conditioned on his right to appeal the denial of his motion to suppress the fruits of a traffic stop on the ground that the stop violated the Fourth Amendment. On appeal, the parties disputed whether Defendant waived his constitutional claim by filing an untimely motion to suppress. The Supreme Court affirmed, holding (1) Defendant did not waive his Fourth Amendment claim; and (2) the district court did not err in denying Defendant's motion to suppress. View "Barney v. State" on Justia Law