Justia Civil Rights Opinion Summaries

Ali sought to pursue 42 U.S.C. 1983 proceedings challenging as unconstitutional an executive order of Maryland’s Governor that prohibits boycotts of Israel by business entities that bid on the state’s procurement contracts. According to the Initial Complaint, “Ali is a computer software engineer who wishes to submit bids for government software project contracts but is barred from doing so due to the presence of mandatory ‘No Boycott of Israel’ clauses.”The district court dismissed with prejudice Ali’s lawsuit for want of Article III standing to sue. The Fourth Circuit affirmed but modified the judgment to provide that the dismissal is without prejudice. The court first disagreed with Ali’s interpretation of the Order. The Order indicates that if a business entity has engaged in anti-Israel national origin discrimination in the process of preparing a bid for a state procurement contract, the entity is barred from being awarded the contract; if the entity has engaged in a boycott of Israel entirely unrelated to the bid formation process, the Order is of no relevance. The court rejected Ali’s argument that the certification requirement constitutes an unconstitutionally vague loyalty oath. The Order does not require the entity to pledge any loyalty to Israel or profess any other beliefs. View "Ali v. Hogan" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence of methamphetamine found in his coat pocket during a traffic stop, holding that the search was unconstitutional, and therefore, the district court erred in denying Defendant's motion to suppress.Defendant was a backseat passenger in a car driven by his brother that was pulled over for a traffic violation. On appeal, Defendant argued that the officer who found methamphetamine in his coat pocket lacked probable cause to search him after a canine indicated drugs were present in the car. The Supreme Court agreed and reversed the denial of Defendant's motion to suppress and vacated his conviction, holding (1) the officers lacked probable cause to arrest Defendant before they searched his person; and (2) therefore, the district court erred by denying Defendant's motion to suppress the evidence found from the unconstitutional search. View "State v. Stevens" on Justia Law

The Supreme Court affirmed Defendant's conviction that arose from the search of her backpack after police officers encountered a stolen car parked with the engine running, holding that the district court did not err in denying Defendant's motion to suppress.Defendant was one of the three backseat passengers in the parked car at issue. The officers observed an open bottle of liquor on the driver's seat and another open container of liquor standing on the rear seat floorboard. When the passengers were directed to exit the vehicle Defendant took her backpack with her. An officer took the backpack, noticed a bag of marijuana, and discovered illicit drugs in a subsequent search. The district court denied Defendant's motion to suppress the results of the search of her backpack on the basis of the automobile exception. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to suppress. View "State v. Rincon" on Justia Law

The First Circuit affirmed Defendant's conviction for being a felon in possession of a firearm, holding that the district court did not err in denying Defendant's motion to suppress.Upon executing a no-knock search warrant following reports of discharged shots the police found two shotguns and related paraphernalia in Defendant's bedroom. In his motion to suppress, Defendant argued that the police exceeded the scope of the warrant by searching his bedroom, which was located on the third floor of the building, because the searched warrant was for "88 Foundation St. 2nd floor." The district court denied the motion, concluding that the good-faith exception to the exclusionary rule applied. The First Circuit affirmed, holding that the officers reasonably believed that the warrant permitted the search of Defendant's third-floor bedroom. View "United States v. Pimentel" on Justia Law

The Wades live in a second-floor apartment; the first-floor unit is a short flight of stairs up from ground level. Chicago Police officers were seeking Johnson, a purported heroin dealer. A confidential informant had identified the “second floor” of the Wades’ building as Johnson’s place of operations. Johnson actually lived on the first floor. No officer confirmed Johnson’s address, surveilled the building, or checked whether anybody else was living in the second-floor unit. Officers obtained a warrant for that unit, ascended both staircases, and kicked in the door. Wade was out. A family friend, Dotson, was at the apartment. Dotson’s account differs from police accounts. Dotson alleges that an officer planted narcotics on his person The officers say that upon entering the apartment they found Dotson and Nero inside. Both fled. Officers caught them on the back porch. Video evidence of the events was lost. A thorough search of the Wades’ apartment turned up no drugs. Large quantities of narcotics were discovered in the downstairs unit.The district court rejected the Wades' suit on summary judgment. Dotson’s claims were settled. The Seventh Circuit affirmed. The Wades have not identified evidence that would allow a reasonable fact-finder to decide in their favor, Given the facially valid warrant and the lack of immediately self-evident ambiguity, the officers were entitled to enter the Wades’ apartment to search. View "Wade v. Ramos" on Justia Law

In 1989, Oliver went to a Los Angeles church during evening service and shot three people, two of whom died. During a jury selection at Oliver’s trial on two counts of first-degree murder with special circumstances and attempted murder, the defense made four unsuccessful “Batson” motions, alleging that the prosecutor used peremptory challenges to strike prospective jurors on the basis of race. Oliver argued that the prosecutor’s stated reason for striking V.H.—that V.H. acquitted in a rape case in his only prior jury service—was pretextual, as evidenced by the disparate treatment of S.P., who was allegedly similar to V.H. except for her race.The district court granted habeas relief. The Ninth Circuit reversed in part. In substituting its own factual findings for those of the state court, the district court neglected to frame the relevant question as whether a fair-minded jurist could reach a different conclusion. The decision of the California Supreme Court was not unreasonable and did not "rubber-stamp” the prosecutor’s proffered explanations or otherwise misapply the law. No U.S. Supreme Court decision establishes that detailed factual findings are required before an appellate court may give deference to a trial court’s Batson ruling. If the trial court’s inquiry was deficient, it was cured by the California Supreme Court’s searching analysis, which included a de novo comparative juror analysis. The court remanded to allow the district court to assess the strikes of three other prospective jurors. View "Oliver v. Davis" on Justia Law

The Supreme Court held that the court of appeals correctly held that the conduct of two court personnel triggered a rebuttable presumption against Defendant, holding that remand was required.The court personnel in this case shared a nonpublic courthouse elevator with a jury during Defendant's trial and either told the jurors to find Defendant guilty and "hang him" or stood quietly in the elevator. On appeal, Defendant argued that the improper juror contact denied him his constitutional right to a fair trial and impartial jury. The court of appeals agreed and reversed Defendant's conviction and remanded the case for a new trial. The Supreme Court affirmed, holding (1) the improper contact violated Defendant's right to an impartial jury and triggered a rebuttable presumption that Defendant was prejudiced by the constitutional error; and (2) the case must be remanded for a determination as to whether the State had met its burden. View "State v. Soto" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court terminating Father's parental rights as to his child, holding that Father was not denied due process and that Father failed to prove his claim of ineffective assistance of counsel.After a hearing, the district court entered an order terminating the parental rights of Mother and Father to their child finding that the parents were unwilling or unable to protect the child from jeopardy or to take responsibility for the child in a time reasonably calculated to meet the child's needs and that termination was in the child's best interest. The Supreme Judicial Court affirmed, holding (1) the trial court's decision to accept a proposed order and findings only from the Department of Health and Human Services did not affect the outcome of the case; and (2) Father was not entitled to relief on his ineffective assistance of counsel claim. View "In re Child of Kenneth S." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of extreme atrocity or cruelty for the killing of his wife, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the prosecutor did not improperly exercise a peremptory challenge to strike a male juror; (2) the trial judge did not abuse her discretion in connection with certain evidentiary decisions; (3) the prosecutor's challenged statements in his closing argument did not create a substantial likelihood of a miscarriage of justice; (4) the jury instruction on mental impairment was sufficient; (5) the denial of Defendant's motion for a new trial did not constitute an abuse of discretion; and (6) this Court declines to exercise its authority under Mass. Gen. Laws 278, 33E, to order a new trial or a reduction in the verdict. View "Commonwealth v. Huang" on Justia Law

A John Doe informant stated that Taylor had showed the informant a gun inside Taylor’s apartment. Taylor was a felon. Chicago police officer Hughes secured a warrant to search Taylor’s apartment. On the record, no one knows Doe’s real name, contact information, or why he came forward Doe knew how to get to Taylor’s apartment, but not his address. Hughes made an incorrect guess. Officers entered Taylor’s apartment, which was not the apartment listed on the warrant. Officers found mail addressed in his name from which they learned the correct address. They found a different gun than was described by Doe. Officers found no evidence directly connecting Taylor to the bedroom in which the gun was found. Hughes initiated an alert for Taylor’s arrest. Taylor turned himself in and spent four months in jail before a court found the warrant invalid based on the address error and quashed his arrest. Despite Taylor’s acquittal, the arrest alert remained active. A month later, Taylor was again arrested.Taylor filed suit, 42 U.S.C. 1983. The district court granted the defendant summary judgment. The Seventh Circuit affirmed as to officers who were not involved in procuring the warrant and affirmed summary judgment for the city on Taylor’s Monell claims relating to the investigative alerts policy and policy with respect to John Doe informants. The court reversed the grant of summary judgment for Hughes and remanded for a determination of damages. Hughes is entitled to good-faith immunity only if he could have “reasonably believed" that the search was authorized by a valid warrant. Hughes told the judge that he knew Taylor’s address; he did not. Hughes stated that there was probable cause to believe drugs would be found in the apartment; there was not. View "Taylor v. Hughes" on Justia Law