Justia Civil Rights Opinion Summaries

The Supreme Court accepted a certified question from the United States Court of Appeals for the Fifth Circuit by answering that Texas law does not authorize certain state officials to directly or indirectly enforce the state's new abortion restriction requirements.Plaintiffs, who provided and funded abortions and support for women who obtain them in Texas, requested a declaration that Senate Bill 8, the "Texas Heartbeat Act," Tex. Health & Safety Code 171.201-.212, unconstitutionally restricted their rights and injunction prohibiting Defendants, state agency executives, from enforcing the Act's requirements. After a remand, the Fifth Circuit certified a question to the Supreme Court. The Supreme Court answered answered that Texas law does not grant the state agency executives named as defendants any authority to enforce the Act's requirements, either directly or indirectly. View "Whole Woman's Health v. Jackson" on Justia Law

The Supreme Court affirmed in part and dismissed in part the order of the district court overruling Appellant's motion for absolute discharge wherein Appellant alleged violations of his statutory and constitutional rights to a speedy trial, holding Appellant was not entitled to relief.Appellant was charged with domestic violence assault in the third degree and strangulation. After several continuances, Appellant filed a motion to discharge on speedy trial grounds. The district court overruled the motion. The Supreme Court affirmed in part and dismissed in part, holding (1) the district court's order was sufficiently specific regarding the causes of the delay and the period of delay; (2) the district court's finding that Appellant's case should not be dismissed on statutory speedy trial grounds was not clearly erroneous; and (3) this Court lacked appellate jurisdiction to review Moody’s claim that he was entitled to absolute discharge on constitutional speedy trial grounds. View "State v. Moody" on Justia Law

The Indiana Department of Correction places offenders in restrictive housing when their continued presence in the general population would pose a serious threat to life, property, and others, or the security and orderly operation of a correctional facility. Crouch has been an Indiana inmate for about a decade. In February 2016, Crouch was assigned to disciplinary restrictive status housing due to disciplinary code violations. Crouch spent almost four years in solitary confinement. Throughout this period, Crouch received dozens of classification and status reports. Crouch did not appeal any of these reports; before entering solitary confinement he was aware of the process to appeal and had done so. Crouch also received regular 30-day reviews. Crouch did not appeal those reviews. Inmates also may raise concerns through an offender grievance or a disciplinary appeal; both processes are explained to inmates during orientation and copies of the policies are available at the facilities’ law libraries.Crouch sued under 42 U.S.C. 1983, alleging violation of his Due Process rights because of his “prolonged placement in solitary confinement” which “did not receive meaningful review.” The district court dismissed because Crouch failed to exhaust his administrative remedies. The Seventh Circuit affirmed. The Prison Litigation Reform Act requires prisoners to exhaust administrative remedies before filing a federal claim about prison conditions. View "Crouch v. Brown" on Justia Law

Zheng became a permanent U.S. resident in 2004. He was a professor at the University of Southern California, Pennsylvania State University, and The Ohio State University and performed research under National Institute of Health (NIH) grants. Zheng had financial and information-sharing ties to Chinese organizations and received grants from the National Natural Science Foundation of China. Including that information on NIH applications would have derailed Zheng’s funding prospects, so Zheng clouded his ties to China. By 2019, the FBI began investigating Zheng. Zheng left for China but federal agents apprehended him in Anchorage.Zheng pleaded guilty to making false statements, 18 U.S.C. 1001(a)(3). Rejecting an argument that the research Zheng completed offset the amount of money lost, the district court calculated a Guidelines range of 37-46 months and sentenced Zheng to 37 months. On appeal, Zheng argued that his counsel was ineffective by not seeking a downward variance based on Zheng’s immigration status as a deportable alien, which would have an impact on the execution of his sentence. The Sixth Circuit dismissed, noting that the record was inadequate to establish ineffective assistance for the first time on direct appeal. Nothing in the record shows counsel’s reasons for making certain strategic decisions or why he advanced one argument over another. View "United States v. Zheng" on Justia Law

The Ninth Circuit affirmed the district court's order denying plaintiffs' motion for preliminary injunctive relief in a putative class action brought by plaintiffs, two teenage transgender individuals who were born female, alleging that a provision of Arizona law, Arizona Administrative Code R9-22-205(B)(4), that precludes coverage for gender reassignment surgeries violates federal law and is unconstitutional. The panel agreed with the district court that plaintiffs sought a mandatory injunction and noted that the standard for issuing a mandatory injunction is high. Based on the preliminary record, the panel concluded that the given facts specific to remaining plaintiff Doe and the irreversible nature of the surgery, Doe had not shown that the district court's findings were illogical, implausible, or without support in inferences that could be drawn from the facts in the record. In this case, defendants had proffered competing expert testimony challenging plaintiffs' assertion that top surgery was for them medically necessary, safe and effective; Doe sought preliminary injunctive relief when he was a minor, which raised concerns as to whether he sufficiently appreciated the consequences of irreversible surgery; and Doe had serious psychiatric issues distinct from, or related to, his gender dysphoria and his expert psychiatrist had not opined as to whether Doe himself was a suitable candidate for surgery and had not met or examined Doe.The panel noted two additional points because there was ongoing litigation in the district court as to the constitutional and statutory challenges. In regard to Doe's claim under the Constitution's Equal Protection Clause, the panel noted that this court had already held in Karnoski v. Trump, 926 F.3d 1180 (9th Cir. 2019), that the level of scrutiny applicable to discrimination based on transgender status was more than rational basis but less than strict scrutiny. Furthermore, the district court's conclusion that the exclusion was not discriminatory as a threshold matter was based on an erroneous reading that Bostock v. Clayton County, 140 S. Ct. 1731 (2020), was limited to Title VII discrimination claims involving employment. View "Doe v. Snyder" on Justia Law

The New Jersey Attorney General, investigating Smith & Wesson under the state's Consumer Fraud Act, issued a subpoena seeking documents related to Smith & Wesson’s advertisements. Instead of producing the documents, Smith & Wesson filed suit in federal court under 42 U.S.C. 1983, alleging the subpoena violated the First, Second, Fourth, Fifth, and Fourteenth Amendments. The state trial court subsequently ordered Smith & Wesson to show cause and threatened the company with contempt and a ban on sales in New Jersey; the court rejected the constitutional arguments presented in the federal suit. Smith & Wesson unsuccessfully sought an emergency stay of production. In federal court, Smith & Wesson added claims that the Attorney General’s suit was “retaliation" for the exercise of its First Amendment right to petition a court for redress.The Attorney General moved to dismiss the federal suit, citing “Younger” abstention. The district court dismissed the complaint, stating “the subpoena-enforcement action involves orders in the furtherance of state court judicial function.” Smith & Wesson eventually produced the subpoenaed documents under a protective order. The Third Circuit vacated the dismissal, citing the district court’s “virtually unflagging obligation . . . to exercise the jurisdiction given.” Abstention was not warranted in this case because the document production order was not “uniquely in furtherance of the state courts’ ability to perform their judicial functions.” View "Smith & Wesson Brands Inc v. Attorney General New Jersey" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Billy Sheppard Jr.'s motion to vacate his conviction of first-degree murder and denied Sheppard's petition for a writ of habeas corpus, holding that the circuit court properly denied postconviction relief for all guilt claims and that Sheppard failed to establish that he was entitled to habeas corpus relief.Sheppard was convicted of first-degree murder and sentenced to death. Sheppard later filed a motion to vacate his conviction and sentence under Fla. R. Crim. P. 3.851. The circuit court granted a new penalty phase but denied Sheppard's claims as to the guilt phase of his trial. Sheppard appealed, raising claims relevant to the guilt phase, and filed a petition for writ of habeas corpus raising two claims of ineffective assistance of counsel. The Supreme Court affirmed the circuit court's order and denied Sheppard's petition for writ of habeas corpus, holding that Sheppard was not entitled to relief on any of his claims. View "Sheppard v. State" on Justia Law

The Fifth Circuit affirmed the district court's dismissal of plaintiffs' action against the TDCJ and several of its officials over prison conditions during the COVID-19 pandemic. Plaintiffs allege that TDCJ failed to provide reasonable accommodations for their co-morbidities and take other precautions against the COVID-19 pandemic and, in so doing, violated their rights under the Eighth and Fourteenth Amendments, the Americans with Disabilities Act, and the Rehabilitation Act.The court concluded that plaintiffs' undisputed failure to exhaust administrative remedies under the Prisoner Litigation Reform Act (PLRA) resolves this case. Considering all the evidence in the light most favorable to plaintiffs, TDCJ's written response to the Step 1 grievance shows that TDCJ's grievance process could provide at least some relief to plaintiffs. The court explained that the process may have been suboptimal, but it was available as a matter of law and thus, plaintiffs were required to exhaust it before bringing this suit. View "Thoele v. Collier" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity to a police officer in an action brought by Marquis Jones's estate, alleging claims under state and federal law after a police officer shot and killed Jones while he was running away from a traffic stop. In this case, the court agreed with the district court that there are two genuine disputes of material fact for the jury: first, whether the officer saw Jones drop the gun when he ordered him to; and second, whether the officer was unreasonable in believing Jones was taking a firing position rather than surrendering. The court stated that, if, construing the evidence most favorably to the estate, the officer knew Jones was unarmed, then shooting him violated a clearly established constitutional right. View "Williams v. City of Burlington" on Justia Law

Price had been convicted of felony aggravated battery. A gunshop employee ran a background check after Price placed an order, then contacted ATF Agent Clancy, and gave Price an inoperable magazine shell. Price purchased ammunition. Price later complained the magazine did not fit “his firearm.” Clancy impersonated a store employee for Price’s return and contacted the Indiana Department of Correction. Parole officers arrived at the store and searched Price's vehicle, as authorized by his parole agreement. They found a (stolen) loaded pistol. Clancy and the parole officers drove Price to his residence. The officers searched, discovered ammunition, and notified Clancy. Clancy obtained and executed a search warrant for the home, a van parked in the driveway, and an outbuilding. Officers found a firearm and ammunition. A rifle was found in the van.Indicted for possessing a firearm as a felon, 18 U.S.C. 922(g)(1), Price unsuccessfully moved to suppress the evidence, arguing the warrantless parole searches violated the Fourth Amendment because the parole officers acted as a “stalking horse” for the ATF, allowing Clancy to circumvent typical warrant and probable cause requirements. The Seventh Circuit affirmed. The parole officers complied with the parole agreement; they had reasonable cause to believe Price had violated his parole conditions. The court also rejected arguments that there was insufficient evidence that Price had constructively possessed the guns and challenges to sentencing enhancements for multiple firearms, a stolen firearm, and obstruction of justice. View "United States v. Price" on Justia Law