Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the post-conviction court concluding that Defendant did not receive ineffective assistance of counsel at sentencing, holding that Defendant did not receive ineffective assistance of counsel.Defendant was convicted of murdering his brother when Defendant was seventeen years old. Defendant sought post-conviction relief alleging that he received ineffective assistance of counsel at sentencing. The post-conviction court denied relief. The Supreme Court affirmed, holding that Defendant did not meet his burden to show that counsel's performance fell objectively below professional norms or that he was prejudiced by any of counsel's alleged errors. View "Conley v. State" on Justia Law

Keles was admitted into Rutgers’s Civil and Environmental Engineering (CEE) Department’s graduate program and received his M.S. degree in 2014. While pursuing this degree, Keles expressed his interest in continuing his studies as a Ph.D. student. To continue their studies as Ph.D. students, M.S. students in the CEE Department must submit a “Change-in-Status” form, identifying advisors and describing their research plans. At the end of the M.S. program, Keles submitted an incomplete Change-in-Status form. Keles disputed that he needed to submit a completed Change-in-Status form due to his claimed enrollment as an M.S.-Ph.D. student. Members of the CEE Department and the University’s administration informed him that he needed to satisfy the admission prerequisites. Keles neither found an advisor nor submitted a completed form but sought to register for classes in 2015. Rutgers’s Administration informed Keles that his lack of academic standing prevented him from registering.Keles sued, alleging contract, tort, statutory, and due process claims. The Third Circuit affirmed the dismissal of his suit, finding that Rutgers adhered to its own policies and did not act in bad faith. All M.S. students were subject to the same departmental requirements. Rutgers afforded Keles sufficient process and did not venture “beyond the pale of reasoned academic decisionmaking.” View "Keles v. Bender" on Justia Law

Ohio's legislatively-established municipal and county courts possess jurisdiction within their territorial limits over certain civil and criminal matters with the same authority as other common pleas judges. Cuyahoga County Juvenile Court employees certified a union as the exclusive collective bargaining representative for 136 employees, not including judges. A 2016 collective bargaining agreement was to extend through December 2019 and stated that the court would respect its terms until the parties reached a new agreement, the union disclaimed the contract, or the employees decertified the union. In 2019, negotiations stalled. In December 2020, the Juvenile Court sought a declaration that the agreements were void or expired. The union counterclaimed for breach of contract. The Juvenile Court subsequently treated union members as nonunion employees, decided to stop deducting union dues from paychecks, imposed new work schedules, and eliminated grievance procedures.The union sued in federal court, citing the Contracts Clause and the Takings Clause. The Sixth Circuit affirmed the dismissal of the suit. Sovereign immunity bars the union’s claims against the Juvenile Court because it is an arm of the State of Ohio. Section 1983 does not provide a cause of action for the union’s Contracts Clause claims against the individual defendants; qualified immunity barred the money-damages claims against them under the Takings Clause. View "Laborers' International Union of North America v. Neff" on Justia Law

The Second Circuit affirmed the district court's denial of summary judgment as to absolute and qualified immunity in an action raising Fourth Amendment claims of false arrest and malicious prosecution brought pursuant to 42 U.S.C. 1983. The court agreed with the district court that absolute prosecutorial immunity did not apply to appellants' participation in obtaining the arrest warrant for plaintiff. The court explained that long-standing precedent makes clear that swearing to an arrest warrant affidavit and executing an arrest are traditional police functions, and performing such functions at the direction of a prosecutor does not transform them into prosecutorial acts protected by absolute immunity.The court also concluded that the district court correctly determined that summary judgment on the issue of qualified immunity was unwarranted given the factual disputes here. In this case, the district court identified relevant and exculpatory omissions from the arrest warrant affidavit related to plaintiff's intent and credibility that, construing the evidence in a manner most favorable to plaintiff, could have materially impacted a magistrate judge's determination as to whether probable cause existed for plaintiff's arrest, and such factual issues preclude summary judgment for appellants on the ground of qualified immunity at this stage of litigation. The court remanded for further proceedings. View "Washington v. Napolitano" on Justia Law

The Supreme Court affirmed the decision of the intermediate court of appeals (ICA) affirming the judgment of the circuit court denying Defendant's motion to suppress evidence, holding that the police officers' actions did not constitute a breaking and that the search of a gray backpack did not exceed the terms of the search warrant in this case.On appeal, Defendant argued that the evidence against him should be excluded because police officers failed to comply with the requirements set forth in Haw. Rev. Stat. 803-37 that officers "demand entrance" before entering a building and because the search of his backpack exceeded the terms of the search warrant executed by the officers. The Supreme Court affirmed, holding (1) the purposes of Haw. Rev. Stat. 803-37 were satisfied when the officers' entry did not create any risk of harm; and (2) the searches of Defendant's backpack did not exceed the terms of the search warrant. View "State v. Keanaaina" on Justia Law

Five adjacent Burtonsville, Maryland parcels are restricted from receiving sewer service. Several previous attempts to obtain approval of water and sewer category change requests were unsuccessful. The owners' alternative plan was to sell to a religious organization. They believed that land-use regulations must submit to “[c]hurch use [which] cannot be denied.” They entered into a contract with Canaan, contingent on the approval of the extension of a public sewer line for a new church. Such an extension required amendment of the Comprehensive Ten-Year Water Supply and Sewerage Systems Plan, which involves the Montgomery County Planning Board, the County Executive, the County Council, public hearings, and the Maryland Department of the Environment.Following denial of their requests, the owners sued under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause of the First Amendment. The Fourth Circuit affirmed the summary judgment rejection of the claims. The land has been bound by decades of regulations restricting development for both religious and non-religious purposes. The parties were aware of the difficulties in developing the property when they entered into the contract; they could not have a reasonable expectation of religious land use. The restrictions are rationally related to the government’s interest in protecting the region’s watershed. View "Canaan Christian Church v. Montgomery County" on Justia Law

In 1984, Friend robbed an Oakland bar and fatally stabbed Pierucci. Convicted of first-degree murder and robbery with a special circumstance, Friend was sentenced to death. The California Supreme Court affirmed the judgment and denied Friend’s state habeas corpus petition.Proposition 66, the Death Penalty Reform and Savings Act of 2016, requires that capital habeas corpus petitions generally be presented to the sentencing court and that a successive habeas corpus petition be dismissed unless the court finds that the petitioner makes a showing of actual innocence or ineligibility for the death penalty. A petitioner may appeal the denial of a successive petition only if the sentencing court or the court of appeal grants a certificate of appealability (COA). The sentencing court denied Friend’s second habeas petition and his request for a COA. The court of appeal denied a COA. The California Supreme Court remanded with directions to analyze whether Friend made a substantial showing that the claims in his second habeas corpus petition are not successive.On remand, the court of appeal again denied relief. Friend essentially acknowledged that all the claims in his second petition were either known or could and should have been discovered earlier and he failed to allege specific facts showing the omission of some claims from the initial petition reflects incompetence of prior habeas counsel. Friend failed to show a substantial claim that he is either actually innocent or ineligible for the death sentence. View "In re Friend" on Justia Law

In 1981, Balla, incarcerated at ISCI, brought a class action suit alleging unconstitutional prison conditions. In 1984, the district court granted injunctive relief related mostly to medical care and physical safety. Since then, the district court has ordered many forms of prospective relief. The district court ultimately held a hearing, found that ISCI had complied with agreed-upon standards and was not deliberately indifferent to the medical needs of patients, and terminated all prospective relief, pursuant to the Prison Litigation Reform Act, 18 U.S.C. 3626(b).The Ninth Circuit affirmed, first rejecting an assertion that the district court abused its discretion in excluding evidence of ISCI's failure to adequately treat the Hepatitis C virus. That evidence did not necessarily answer whether there was an ongoing constitutional violation related to the general provision of healthcare that was required by prior orders. The district court did not clearly err in finding no evidence that ISCI medical staff made choices in conscious disregard of an excessive risk to the plaintiffs’ health; the conditions at the Medical Annex did not rise to the level of an Eighth Amendment violation because there was no deliberate indifference. There was no evidence there were ongoing problems of the sort that motivated previous population caps and security staffing orders. View "Balla v. Idaho" on Justia Law

New Harvest challenged a Salinas ordinance prohibiting religious and other assemblies from operating on the ground floor of buildings facing Main Street within the downtown area. The ordinance prohibited it from hosting worship services on the ground floor of its newly-purchased building. New Harvest claimed the ordinance substantially burdened its religious exercise and treated New Harvest on less than equal terms with nonreligious assemblies, in violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc. The district court granted the city summary judgment. New Harvest sold the building; the Ninth Circuit treated claims for declaratory and injunctive relief as moot.Addressing claims for damages, the court reversed in part. The ordinance facially violated RLUIPA's equal terms provision. Other nonreligious assemblies, such as theatres, are permitted to operate on the first floor of the Restricted Area and are similarly situated to religious assemblies with respect to the provision’s stated purpose and criterion. New Harvest failed to demonstrate a substantial burden on its religious exercise; it could have conducted services on the second floor or by reconfiguring the first floor and was not precluded from using other available sites within Salinas. When it purchased the building, New Harvest was on notice that the ordinance prohibited services on the first floor. View "New Harvest Christian Fellowship v. City of Salinas" on Justia Law

In an action stemming from a land transaction dispute, the Fifth Circuit reversed as to federal and state qualified immunity and affirmed the denial of discretionary immunity under Louisiana law. The court held that the sheriff is entitled to qualified immunity barring plaintiff's 42 U.S.C. 1983 claim that the sheriff's improper management of the sheriff's sale of property in which plaintiff claimed an interest violated her protected rights. In this case, plaintiff failed to allege any personal involvement of the sheriff in the purported wrongdoing. However, on the sheriff's claim to discretionary immunity under Louisiana law, the court held that the district court did not abuse its discretion in finding that the sheriff failed to timely raise the defense before that court. View "Magnolia Island Plantation, LLC v. Whittington" on Justia Law