Justia Civil Rights Opinion Summaries

See is a law-enforcement officer for the Illinois Gaming Board, which often hires State Police officers. As a union representative, See expressed concern that the Board’s promotion policies gave State Police employees unfair advantages. See then began to exhibit signs of paranoia. He complained to Board management that his supervisor was spreading malicious rumors about him to intimidate and scare him. He said that his wife was “seriously afraid” that the State Police would harm them. Management became concerned about his mental stability and placed him on administrative leave pending an examination of his fitness for duty. A few weeks later See passed the examination and returned to work.See filed suit under 42 U.S.C. 1983 alleging retaliation for exercising his First Amendment rights and discrimination under the Americans with Disabilities Act (ADA), section 12112, by requiring him to undergo a medical examination without a job-related justification. The Seventh Circuit affirmed summary judgment for the defendants. Even if See established a prima facie case of retaliation, the defendants offered a legitimate, nonretaliatory reason for placing him on leave and requiring a fitness-for-duty examination: they were genuinely concerned about his mental health. See presented no evidence that this reason was pretextual. See is an armed law enforcement officer, so the possibility of mental instability posed a serious public-safety concern the examination was job-related and consistent with business necessity. View "See v. Illinois Gaming Board" on Justia Law

Becker’s pregnant girlfriend was shot to death on August 12, 2011. In an interview immediately after the shooting, Becker waived his Miranda rights and stated that he only wanted to clean the gun and “play around.” On August 18, after Becker’s discharge from a psychiatric hospital, he went voluntarily for a second interview. In a video-recorded interview, police repeated the Miranda warnings and neither placed Becker in handcuffs nor arrested him. The door to the interview room was unlocked. Police offered Becker drinks, cigarettes, and breaks. After approximately one hour, Becker stated: “I have nothing more to say ‘cause no matter what I say, youse trying to make me something I’m not.” Investigators left the room for several minutes. About an hour later, Becker responded to questions regarding his abusive history: “OK. I’m done now.” He never explicitly asked or attempted to leave. Police continued to question Becker, who was convicted of murder in the first degree and murder in the third degree. Becker unsuccessfully appealed the denial of his motion to suppress the second interview.The district court rejected his federal habeas petition and found “no basis” for a Certificate of Appealability (COA). The Third Circuit affirmed, applying the Antiterrorism and Effective Death Penalty Act, 28 U.S.C. 2254 deferential standard to the state trial court’s findings when considering a request for a COA. Becker cannot meet that standard. View "Becker v. Secretary Pennsylvania Department of Corrections" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of sexual assault in the first and fourth degree, attempt to commit sexual assault in the first degree, and two counts of risk of injury to a child, holding that there was no error in the proceedings below.On appeal, Defendant argued (1) the trial court erred in overruling his objection brought pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), objecting to the prosecutor's exercise of peremptory challenges to two prospective members of the jury; and (2) his conviction for risk of injury to a child violated constitutional double jeopardy protections. The Supreme Court affirmed, holding (1) the trial court did not commit clear error in determining that Defendant failed to meet his burden of proving by a preponderance of the evidence that the jury selection process in his case was tainted by purposeful discrimination; and (2) Defendant's conviction for two counts of risk of injury did not violate his right to be free from double jeopardy. View "State v. Jose A.B." on Justia Law

The LA Times appeals the district court's denial of its motions to unseal court records relating to a search warrant allegedly executed on Senator Richard Burr in connection with an insider-trading investigation and the government's memorandum opposing its motion to unseal.The DC Circuit remanded the case to the district court to reconsider its common law analysis in light of new disclosures from a related investigation by the SEC and Senator Burr's public acknowledgment of the Justice Department's investigation, as well as precedent governing how the common law right should be balanced against competing interests. The district court shall reconsider the L.A. Times' challenge that it was fundamentally disadvantaged by the district court's decision to seal the government's opposition memorandum and attached exhibits. View "Los Angeles Times Communications LLC v. United States" on Justia Law

The Supreme Court affirmed the orders of the trial court terminating Mother's parental rights to her daughter, holding that there was no error. After a termination hearing, the trial court determined that grounds existed to terminate Mother's parental rights under N.C. Gen. Stat. 7B-1111(a)(1) and (2) and that it was in the child's best interests to terminate Mother's parental rights. On appeal, Mother argued that the trial court erred by concluding that terminating her parental rights was in the child's best interests. The Supreme Court affirmed, holding that the court did not abuse its discretion by determining that termination of Mother's parental rights was in the child's best interests. View "In re H.R.S." on Justia Law

The Second Circuit affirmed the district court's dismissal of plaintiff's complaint, alleging violations of regulations promulgated pursuant to the Americans with Disabilities Act of 1990 (ADA). Plaintiff, who uses a wheelchair and is disabled, did not assert in the complaint that he visited West Point Realty's website with the intention of visiting the hotel run by West Point Realty; rather, he alleged that he frequently visits hotel websites to determine whether those websites comply with ADA regulations. The court agreed with the district court that plaintiff failed to allege a concrete injury in fact and therefore lacked standing to assert a claim under the ADA. The court also concluded that the district court did not abuse its discretion by considering only the allegations in plaintiff's complaint when deciding West Point Realty's motion to dismiss. View "Harty v. West Point Realty, Inc." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court convicting Defendant of various drug-related crimes and sentencing him to a total of forty-two years in prison, holding that the district court did not err in denying Defendant's motion to suppress.At issue on appeal was whether the grant of a search warrant to search Defendant's residence and vehicles for evidence of drug dealing had a substantial basis under the totality of the circumstances, as disclosed in the warrant application. The Supreme Court held that the magistrate's determination that the information was sufficient to justify a search warrant for the house had a substantial basis, and therefore, the district court did not err in denying Defendant's motion to suppress. View "State v. Bracy" on Justia Law

Riley’s Farm provides historical reenactments and hosts apple picking. In 2001-2017, schools within the District took field trips to Riley’s. In 2018, Riley used his personal Twitter account to comment on controversial topics. Parents complained; a local newspaper published an article about Riley and his postings. The District severed the business relationship. In a 42 U.S.C. 1983 suit alleging retaliation for protected speech, the district court granted the District defendants summary judgment.The Ninth Circuit reversed as to injunctive relief but affirmed as to damages. Riley made a prima facie case of retaliation; he engaged in expressive conduct, some of the District defendants took an adverse action that caused Riley to lose a valuable government benefit, and those defendants were motivated by Riley’s expressive conduct. There was sufficient evidence that Board members had the requisite mental state to be liable for damages. The defendants failed to establish that the District’s asserted interests in preventing disruption to their operations and curricular design because of parental complaints outweighed Riley’s free speech interests. Even assuming that the selection of a field trip venue was protected government speech, the pedagogical concerns underlying the government-speech doctrine did not apply because Riley was not speaking for the District. Nonetheless, the defendants were entitled to qualified immunity on the damages claim. There was no case directly on point that would have clearly established that the defendants’ reaction to parental complaints and media attention was unconstitutional. View "Riley’s American Heritage Farms v. Elsasser" on Justia Law

The SmileDirect parties developed an online service model for patients to access certain orthodontic services; they allege the defendants (members and employees of the California Dental Board) conspired to harass them with unfounded investigations and an intimidation campaign, to drive them out of the market. The district court dismissed the suit. The Ninth Circuit reversed with respect to certain Sherman Act antitrust claims. The SmileDirect parties sufficiently pled Article III standing; they alleged an injury in fact that was fairly traceable to defendants’ challenged conduct and was judicially redressable. They sufficiently alleged anticompetitive concerted action, or an agreement to restrain trade. The court rejected an argument that regulatory board members and employees cannot form an anticompetitive conspiracy when acting within their regulatory authority.The court affirmed the dismissal of a claim under the Dormant Commerce Clause, which prohibits states from discriminating against interstate commerce, and of a "disparate treatment" Equal Protection Clause claim. To plead a class-of-one equal protection claim, plaintiffs must allege that they have been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment. A class-of-one plaintiff must be similarly situated to the proposed comparator in all material respects. Rather than claiming that they stood on the same footing as others, the SmileDirect parties argued their uniqueness. View "Sulitzer v. Tippins" on Justia Law

CalChamber filed suit, 42 U.S.C. 1983, to “vindicate its members’ First Amendment rights to not be compelled to place false and misleading acrylamide warnings on their food products.” The district court entered a preliminary injunction, prohibiting the Attorney General and related entities, including private enforcers from pursuing new lawsuits to enforce Proposition 65's requirement that “[n]o person in the course of doing business shall knowingly and intentionally expose any individual to a chemical known to the state to cause cancer . . . without first giving clear and reasonable warning.”The Ninth Circuit affirmed. CalChamber was likely to succeed on the merits of its compelled speech claim. Given the robust disagreement by reputable scientific sources over whether acrylamide in food causes cancer in humans, the warning was controversial and misleading. Proposition 65’s enforcement regime created a heavy litigation burden on manufacturers who use alternative warnings rather than the regulatory safe harbor warning. The serious constitutional issue provided sufficient reason to enjoin Proposition 65 acrylamide litigation until the case was finally decided; the injunction was not an impermissible prior restraint. CalChambers established irreparable harm, and the scope of the injunction was not impermissible; and the balance of hardships weighed in CalChamber’s favor. The injunction was in the public interest. View "California Chamber of Commerce v. Council for Education and Research on Toxics" on Justia Law