Justia Civil Rights Opinion Summaries

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

Plaintiff, a temporary employee on a construction job suffered a diabetic attack at work. Six days later, the plaintiff was terminated along with several others. After exhausting her administrative remedies, the plaintiff sued her employer in the Eastern District of Texas, bringing claims for damages under the ADA, alleging she had been discriminated against due to her diabetes.The circuit court found that the evidence was that plaintiff was terminated immediately after an event that highlighted her ADA-protected disability. The court reasoned proximity of her diabetic episode on the job and her termination was sufficient to constitute a prima facie case that she was included in the group to be terminated for ADA violative reasons. The court further found that plaintiff has presented evidence sufficient to rebut the defendant’s nondiscriminatory reason for termination and show that a fact question exists as to whether that explanation is pretextual. Thus, the plaintiff established the elements of her prima facie case and she has also presented “substantial evidence” that the defendant’s nondiscriminatory rationale for her inclusion in the reduction in force was pretextual. An issue of material fact remains regarding whether the defendant discriminated against the plaintiff on the basis of her disability by including her in the reduction of force. View "Gosby v. Apache Industrial" on Justia Law

Battle Creek Officers Ziegler and Kerschen stopped LaPlante’s vehicle. LaPlante's passenger, Robbins, exited the vehicle. As Kerschen dealt with Robbins, LaPlante exited the vehicle with an open beer and did not comply with orders to put the beer down and stop moving. Ziegler eventually pulled LaPlante to the ground in a prone position. The officers struggled to handcuff LaPlante. It took approximately 90 seconds to effectuate LaPlante’s arrest. Ziegler notified dispatch that LaPlante was experiencing pain and loosened the handcuffs at LaPlante’s request. LaPlante was transported to a hospital before being taken to jail. LaPlante had dislocated his elbow and sustained a small avulsion fracture. LaPlante pleaded guilty to felony DUI and a high misdemeanor charge of attempted obstruction of a police officer. LaPlante had an outstanding felony warrant for absconding parole and the officers recovered marijuana from LaPlante’s vehicle. LaPlante subsequently sought medical support for a variety of injuries.In his 42 U.S.C. 1983 excessive force action, LaPlante alleged that Ziegler threw him to the ground and Kerschen failed to intervene. The Sixth Circuit affirmed the denial of qualified immunity as to Ziegler and reversed the denial of qualified immunity as to Kerschen. There is a genuine issue of material fact as to whether LaPlante resisted arrest; the use of a takedown maneuver, in some scenarios, can amount to excessive force. Kerschen did not have enough time to perceive what was going on and intervene. View "LaPlante v. City of Battle Creek" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree murder, use of a firearm to commit a felony, and possession of a firearm by a prohibited person, holding that Defendant failed to show that he was entitled to relief on his claims of error.On appeal, Defendant argued that the district court erred in concluding that he was competent to stand trial and erred in admitting evidence that Defendant alleged was obtained in violation of his Fourth Amendment rights. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the district court's conclusion that Defendant was competent to stand trial; and (2) there was no merit to Defendant's second and third assignments of error. View "State v. Surber" on Justia Law

Plaintiffs challenged President Biden’s September 9, 2021 order requiring all executive employees to receive the COVID-19 vaccination. After finding that the equities favored the plaintiffs and that they were likely to succeed at trial, the district court preliminarily enjoined enforcement of President Biden’s Order nationwide.The Fifth Circuit reversed the district court’s prelamination injunction. The Civil Service Reform Act of 1978 (“CSRA”) provides “comprehensive and exclusive procedures” for the review of employment-related disputes between civil-service employees and the federal government. The court held that the CSRA provides meaningful administrative review of the plaintiff’s claims. Because the plaintiffs failed to exhaust available review under the CRSA, the district court lacked jurisdiction to hear the plaintiffs’ claim. The court also rejected the plaintiffs' argument that their claim was "wholly collateral" to the CSRA scheme. View "Feds for Medical Freedom v. Biden" on Justia Law

Plaintiff, an Iraq War veteran, suffered from post-traumatic stress disorder. Two sheriff’s deputies conducted a welfare check after a report that the plaintiff had slit his wrist with a knife. When the deputies arrived, the plaintiff was calm and posed no threat to them. Although the plaintiff expressed his willingness to be arrested, one of the deputies suddenly body-slammed him headfirst, causing a serious neck injury.The Eleventh Circuit held that the deputy had probable cause to seize the plaintiff; therefore, the deputy and supervisor are entitled to qualified immunity from unlawful seizure claims. However, the deputy is not entitled to qualified immunity because the way he did so was excessive. The plaintiff satisfied his burden of proving that the supervisor violated his constitutional right, and the right was clearly established at the time of the alleged violation. Therefore, the sheriff's supervisor was not entitled to qualified immunity from the plaintiff’s claim of supervisory liability. Finally, vicarious liability is unavailable under the Title II of the Americans with Disabilities Act. View "Kirby Ingram v. Louis Kubik, et al." on Justia Law

The Supreme Court reversed Appellant's conviction of multiple child sexual assault and abuse counts, holding that the district court's decision denying Appellant's motion to substitute counsel violated his Sixth Amendment right to counsel.In this twenty-two-count criminal matter Appellant retained Mitchell Posin as defense counsel. On the eve of trial, Appellant filed a motion to substitute counsel, alleging that Posin failed adequately to prepare the defense. The district court denied the motion, and a jury convicted Appellant of most of the counts. The Supreme Court reversed, holding (1) the district court applied the wrong test in deciding Appellant's motion to substitute counsel because Posin was retained, not appointed; and (2) under the appropriate test, the district court abused its discretion by denying the motion to substitute counsel. View "Brass v. State" on Justia Law

The Supreme Court affirmed Defendant's sentence imposed in connection with his plea of guilty to attempted first-degree murder and commission of a felony with a firearm, holding that the sentence did not violate the Eighth Amendment, nor was it an abuse of the circuit court's sentencing discretion.Defendant and the State entered into a plea agreement under which Defendant agreed to plead guilty to attempted first-degree murder and commission of a felony with a firearm. After a sentencing hearing, the circuit court sentenced Defendant to a total of thirty years in prison. The Supreme Court affirmed, holding that the circuit court (1) did not abuse its discretion in imposing the sentence, and (2) Defendant failed to demonstrate that his sentence transgressed the Eighth Amendment's prohibition against cruel and unusual punishment. View "State v. Deleon" on Justia Law

Under Michigan abortion law, a minor may bypass the parental-consent requirement by obtaining a court order granting the right to self-consent (for mature minors) or judicial consent (for “best interests” minors). When the plaintiff sought to apply for judicial bypass, the defendant hadn’t heard of the process and told the plaintiff to come back later. Plaintiff sued the defendant in her individual and official capacities under 42 U.S.C. § 1983, alleging that defendant’s refusal to allow her to apply for a judicial bypass without parental notification violated her Fourteenth Amendment rights. The district court denied the motion when the defendant moved for summary judgment, invoking quasi-judicial and qualified immunity.Before the Eighth Circuit, the defendant claimed she acted at the direction of the Associate Circuit Judge (“Judge”). The Judge testified that he did not recall telling the defendant not to accept the application without parental consent. The circuit court concluded there was a genuine issue of material fact regarding the Judge’s practice of giving pre-filing directions. Further, the is a clearly established right to apply for a judicial bypass. Thus the circuit court declined to address the defendant’s other arguments regarding qualified immunity. View "Jane Doe v. Michelle Chapman" on Justia Law

Moon was charged with domestic battery for causing bodily harm to a minor. Before jury selection, the court typically administers a voir dire oath to prospective jurors but the record does not establish whether the court administered a voir dire oath before or during jury selection. The circuit court asked each potential juror several questions. All the prospective jurors indicated that they would follow the court's instructions. After jury selection, the court asked the circuit clerk to swear the jury in. There is no verbatim record of the oath but the parties stipulated that the clerk incorrectly asked the already-selected jurors: “[D]o you solemnly swear or affirm you’ll truthfully answer all questions asked concerning your qualifications as jurors?” Before his conviction, Moon did not object to the unsworn status of the jury. Denying a post-trial motion, the circuit court concluded that the error was harmless. The appellate court concluded that Moon had forfeited and was not prejudiced by this “clear error.”The Illinois Supreme Court held that reversal of Moon’s conviction is required, regardless of the strength of the evidence or any showing of prejudice. Swearing the jury with a trial oath was essential to the common-law system of trial by jury; deprivation of this constitutional right amounts to structural error. A jury must be sworn with an oath that substantially incorporates specific elements. Because jeopardy never attached, the state is not precluded from retrying the defendant on remand. View "People v. Moon" on Justia Law