Justia Civil Rights Opinion Summaries

Thompson was living with his fiancée and their newborn baby in a Brooklyn apartment. Thompson’s sister-in-law, apparently suffering from mental illness, called 911 to report that Thompson was sexually abusing the baby. When Emergency Medical Technicians arrived, Thompson denied that anyone had called 911. The EMTs returned with police officers, Thompson told them that they could not enter without a warrant. The police nonetheless entered. Thompson was arrested and charged with obstructing governmental administration and resisting arrest. EMTs took the baby to the hospital where medical professionals examined her and found no signs of abuse. Thompson was detained for two days. The charges against Thompson were dismissed without any explanation. The Second Circuit affirmed the dismissal of Thompson’s 42 U.S.C. 1983 claim.The Supreme Court reversed, resolving a split among the Circuits. To demonstrate favorable termination of criminal prosecution for purposes of a section 1983 Fourth Amendment malicious prosecution claim, a plaintiff need not show that the criminal prosecution ended with some affirmative indication of innocence but need only show that his prosecution ended without a conviction. The American tort-law consensus as of 1871 did not require a plaintiff in a malicious prosecution suit to show that his prosecution ended with an affirmative indication of innocence; similarly construing Thompson’s claim is consistent with “the values and purposes” of the Fourth Amendment. Questions concerning whether a defendant was wrongly charged, or whether an individual may seek redress for wrongful prosecution, cannot reasonably depend on whether the prosecutor or court explained why charges were dismissed. Requiring a plaintiff to show that his prosecution ended with an affirmative indication of innocence is not necessary to protect officers from unwarranted civil suits. View "Thompson v. Clark" on Justia Law

The Supreme Judicial Court held that "tower dumps" are not per se unconstitutional and that investigators may use tower dumps so long as they comply with the warrant requirements of article 14 of the Massachusetts Declaration of Rights.The Commonwealth obtained search warrants for seven different "tower dumps," a law enforcement tool that provides investigators with the cell site location information for all devices that connected to specific cell towers during a particular time frame, corresponding to the locations of several crimes. Defendant was ultimately charged with six robberies and a homicide. Defendant moved to suppress all evidence obtained from the tower dumps as the fruit of an unconstitutional search. The superior court judge denied the motion. The Supreme Judicial Court reversed in part, holding (1) investigators may use tower dumps so long as they comply with the warrant requirements of article 14; (2) the second of the two warrants in this case was supported by probable cause and therefore did not offend the Massachusetts Declaration of Rights; but (3) the first warrant was not supported by probable cause, and any evidence obtained from it must be suppressed. View "Commonwealth v. Perry" on Justia Law

Gaddis cut branches from McCombs’s tree that extended into his yard and threw them into McCombs’s yard. McCombs asked Gaddis to pick up the branches but he ignored her. Upon learning that a neighbor, Winstead, had spoken to McCombs about the branches Gaddis went to Winstead’s home and told Winstead to mind his own business. McCombs called the police. Officers arrived. After talking to neighbors, they told Gaddis through the door that he was being arrested for disorderly conduct. Gaddis refused to come out of his home. He stepped outside after officers stated he could also be charged with resisting arrest. Gaddis was arrested for disorderly conduct. Neighbors claimed that Gaddis was erratic and threatening. Gaddis brought a 42 U.S.C. 1983 action against the officers, the city of Marion, and the neighbors, asserting false arrest.The Seventh Circuit affirmed summary judgment in favor of the defendants. The police report provides ample information from which officers could have reasonably believed probable cause existed to arrest Gaddis for disorderly conduct. The consensual discussions between the officers and Gaddis did not amount to a “seizure.” At the time of Gaddis’s arrest, it was not clearly established that the officers’ statements that he would be charged with resisting arrest, followed by his choice to come out and face arrest, would violate the Fourth Amendment’s prohibition on routine warrantless arrests inside the home. View "Gaddis v. DeMattei" on Justia Law

Under its Social Media Policy, Defendants, the Palm Beach County Fire Rescue Department, disciplined appellants, two firefighters who work for the department. The termination resulted from an exchange the appellants had on an invitation-only social medial page associated with one of Appellant’s campaigns for the presidency of the local firefighters’ union. Appellants accused Defendants of conspiring to misuse member-donated paid time off. The court reviewed the case by examining four factors developed from Pickering v. Board of Education, 391 U.S. 563 (1968), and Connick v. Myer, 461 U.S. 138 (1983). The court held that the district court (“DC”) erred in finding that Appellants’ speech did not address a matter of public concern at step one of the four-part test.Further, the Eleventh Circuit affirmed the DC’s dismissal of Appellants’ free-association claim, finding that it is a free speech claim at its core. Finally, the court found that the Social Media Policy in question suffers from “astonishing breadth,” as it expressly prohibits “disseminating content” that “could be reasonably interpreted as having an adverse effect upon Fire Rescue morale, discipline, operations, the safety of staff, or perception of the public.” The court vacated the DC’s summary judgment on the overbreadth claim and affirmed the DC’s decision rejecting Appellants’ facial-vagueness claim. View "AJ O'Laughlin, et al. v. Palm Beach County" on Justia Law

The Supreme Court affirmed Defendant's convictions of felony possession of methamphetamine, misdemeanor possession of drug paraphernalia with intent to use, and misdemeanor theft, holding that the district court did not err in denying Defendant's motion to suppress.Defendant was detained at Walmart for trying to leave the store without paying for merchandise. Defendant was arrested and taken to jail, where a booking deputy conduct an inventory search of Defendant's possessions. Upon discovering illicit drugs the deputy did a strip search of Defendant's person, discovering more illicit drugs. Defendant moved to suppress the drugs and paraphernalia based on an illegal misdemeanor arrest. The motion was denied, and Defendant was convicted. On appeal, Defendant argued that the evidence should have been suppressed because the officer illegally arrested her rather than issuing her a notice to appear. The Supreme Court affirmed, holding that the officer had probable cause to believe Defendant committed misdemeanor theft and would not be apprehended. View "State v. Goodro" on Justia Law

In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of second-degree murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because his jury pool contained only two African-Americans, one of whom was later excused. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Williams" on Justia Law

In this criminal action, the Supreme Court affirmed the ruling of the district court on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury, holding that Defendant's conviction of two counts of murder in the first degree and one count of attempted murder stands.On appeal, Defendant, an African-American, argued that his right to an impartial jury under the United States Constitution had been violated because, although his jury pool contained five African-Americans, the jury that decided his case contained no African-Americans. The Supreme Court made refinements to how a defendant must prove a fair-cross-section constitutional violation and remanded the case to give Defendant an opportunity to develop his impartial-jury arguments. On remand, the district court rejected Defendant's further-developed claims. The Supreme Court affirmed, holding that the district court did not err in ruling on remand that Defendant failed to prove a violation of his Sixth Amendment right to an impartial jury. View "State v. Veal" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Employer's motion for a new trial and motion for judgment notwithstanding the verdict following a jury trial on Employee's claims of sex and gender identity discrimination and dismissing Employee's claims against a third-party administrator on summary judgment, holding that the court erred in part.Specifically, the Supreme Court (1) reversed the district court's denial of Employer's motion for judgment notwithstanding the verdict and dismissed the jury's verdict as to Employee's sex discrimination claims, holding that the district court erred in submitting the sex discrimination claim to the jury; (2) affirmed the jury's verdicts as to employee's gender identity discrimination claims; (3) affirmed the jury's damages award in favor of Employee in the full amounts that the jury entered; and (4) affirmed the district court's grant of summary judgment in favor of Employer. View "Vroegh v. Iowa Department of Corrections" on Justia Law

The Supreme Judicial Court vacated the order of the superior court judge allowing the forfeiture in this case, holding that firearms found to be improperly secured according to the requirements of Mass. Gen. Laws ch. 140, 131L are not subject to forfeiture under Mass. Gen. Laws ch. 276, 3(b), which regulates the disposal of certain firearms seized during the execution of a search warrant.Police obtained a search warrant to search Defendant's home for a firearm allegedly used in an altercation. During the search, officers found that some of Defendant's more than 240 firearms appeared to be improperly secured. Defendant was subsequently indicted on twenty-seven counts of improperly securing a firearm and convicted on twelve counts. Defendant later moved for the return of all twenty-seven of the seized firearms. A superior court judge ordered the return of the firearms seized during during the execution of the search warrant with the exception of the twelve that had been found to have been improperly secured, which the judge ordered be forfeited and destroyed. The Court of Appeals vacated the order below, holding that Mass. Gen. Laws ch. 140, 129D applies only to firearms "deliver[ed] or surrender[ed]," not to those seized during a lawful search. View "Commonwealth v. Fleury" on Justia Law

Appellant filed a 42 U.S.C. 1983 suit against Williamson County, Texas (“County”), alleging that county prosecutors denied him due process secured by the Fourteenth Amendment by lying to his counsel during plea negotiations, misconduct caused by the County’s “closed-file” policy. Appellant alleged that both his Brady and due process claims were enabled by the county’s closed-file policy, which prevented his attorneys from examining evidence, leading him to involuntarily plead guilty. The circuit court reasoned that they could not conclude that the closed-file policy caused the prosecutors to lie. Thus he failed to create a triable issue on the causal connection demanded by Monell. Further, the court held that the appellant’s Brady claim is foreclosed. They reasoned that this court’s precedent has consistently held that Brady focused on the integrity of trials and did not reach pre-trial guilty pleas. The circuit court affirmed the magistrate’s grant of summary judgment as there is no showing that a county policy was the force behind the appellant’s constitutional violation argument. View "Mansfield v. Williamson Cty" on Justia Law