Justia Civil Rights Opinion Summaries

North Carolina inmate Moskos asked Officer Hardee for permission to cross the prison yard to get cold water. Hardee denied this request. Shortly thereafter, Moskos encountered Officer Butler, who allowed him to use a nearby cooler. Returning, Moskos encountered Hardee again. According to Butler and Hardee, Moskos attacked Hardee. Officer Horne ran to the scene and used pepper spray when Moskos refused to stop. According to Moskos, he had threatened to file a grievance against Hardee and Hardee struck him in the head without warning. Moskos complained that his eyes were burning, and according to an officer, he was given a shower within 30-45 minutes, subjected to a full medical assessment, then transferred to a medical center. Moskos disputes the timing and claims that when he returned from the hospital, he was placed in a segregation unit with horrible conditions and not allowed to shower or shave for about 20 days. Moskos was found guilty of assault on an officer, profane language, and disobeying an order. He lost 15 good-credit days, was sentenced to 60 days in segregation, and was transferred to a maximum-level security facility,Moskos unsuccessfully submitted a prison grievance then filed suit under 42 U.S.C. 1983. The Fourth Circuit affirmed judgment as a matter of law for the defendants on his deliberate indifference and due process claims and a defense jury verdict on the remaining claims. View "Moskos v. Hardee" on Justia Law

Under California law, citizens can only obtain firearms and ammunition in person at government-approved gun and ammunition shops. After purchasing a firearm, they must wait a minimum of 10 days to obtain it. Ventura County issued COVID-19 pandemic public health orders that mandated a 48-day closure of gun shops, ammunition shops, and firing ranges, while allowing other businesses like bike shops to remain open. The Orders also prohibited everyone from leaving their homes other than for preapproved reasons, which did not include traveling to gun or ammunition shops or firing ranges outside Ventura County.The Ninth Circuit reversed the dismissal of a challenge to the Orders. The Orders “burdened conduct protected by the Second Amendment, based on a historical understanding of the scope of the Second Amendment right” and failed to satisfy any level of heightened scrutiny. They were not the least restrictive means to further the governmental interest, especially when compared to businesses that had no bearing on fundamental rights, yet were allowed to remain open. The County failed to provide any explanation suggesting that gun shops, ammunition shops, and firing ranges posed a greater risk of spreading COVID-19 than other businesses and activities nor any evidence that it considered less restrictive alternatives. The Orders imposed a far greater burden than California’s 10-day waiting period. View "McDougall v. County of Ventura" on Justia Law

The Supreme Court affirmed the judgment of the habeas court dismissing Defendant's application for habeas corpus, holding that the court did not err.A jury convicted Defendant of fourteen sex offenses. On appeal, Defendant argued that his due process right to jury unanimity was denied and that the prosecutor's remarks during opening statement denied him a fair trial. The Supreme Court affirmed. Defendant later filed an application for writ of habeas corpus alleging ineffective assistance of counsel based on the errors he alleged on appeal. The habeas court dismissed the application. The Supreme Court affirmed, holding (1) Defendant was precluded from demonstrating prejudice for Strickland purposes in a subsequent habeas corpus proceeding; and (2) the habeas court properly dismissed Defendant's amended application for a writ of habeas corpus on summary judgment. View "Neels v. Dooley" on Justia Law

The Landowners own parcels of land adjacent to a 2.45-mile strip of a Union Pacific railroad line in McLennan County, Texas. Union Pacific’s predecessor in interest, Texas Central originally acquired the Line in 1902 through multiple deeds executed by the Landowners’ predecessors in interest. The Landowners sued, seeking compensation based on a theory that their predecessors in interest had conferred only easements to Texas Central, and that the Surface Transportation Board (STB) enforcement of the National Trails System Act, 16 U.S.C. 1241, by “railbanking” amounted to a “taking” of their property. Railbanking involves the transition of unused railroad corridors into recreational hiking and biking trails, generally by a transfer of an interest in the use of a rail corridor to a third-party entity. The Claims Court interpreted the deeds as having conveyed fee simple estates, not easements.The Federal Circuit affirmed. No takings from the Landowners occurred when the government later authorized conversion of the railroad line to a recreation trail; the granting clauses of the subject deeds unambiguously conveyed fee simple interests in the land and not easements despite contradictory language elsewhere in the deeds. View "Anderson v. United States" on Justia Law

A stray 9-millimeter bullet killed a child after a Bronx street fight. Eyewitnesses described the shooter as wearing a blue shirt or sweater. Police officers determined Gilliam was involved and that Morris was at the scene. A search of Morris’ apartment revealed a 9-millimeter cartridge and .357-caliber bullets. Gilliam initially identified Morris as the shooter but subsequently said that Hemphill was the shooter. Morris was charged with murder and possession of a 9-millimeter handgun. The prosecution agreed to dismiss the murder charges if Morris pleaded guilty to possession of a .357 revolver. Years later, Hemphill was indicted for the murder; his DNA matched a blue sweater found in Morris’ apartment shortly after the murder. Hemphill elicited testimony that police had recovered 9-millimeter ammunition from Morris’ apartment, pointing to Morris as the culprit. Morris was not available to testify. The court allowed the prosecution to introduce parts of Morris’ plea allocation transcript to rebut Hemphill’s theory, reasoning that although Morris’ out-of-court statements had not been subjected to cross-examination, Hemphill’s arguments had “opened the door” and admission of the statements was reasonably necessary to correct a misleading impression. Hemphill was convicted. The Supreme Court reversed. Admission of the plea allocution transcript violated Hemphill’s Sixth Amendment right to confront the witnesses against him. While the Sixth Amendment permits reasonable procedural rules concerning the exercise of a defendant’s confrontation right, the “door-opening principle” is a substantive principle that dictates what material is relevant and admissible. It was not for the trial judge to determine whether Hemphill’s theory that Morris was the shooter was unreliable, incredible, or otherwise misleading in light of the state’s proffered, unconfronted plea evidence, nor whether this evidence was reasonably necessary to correct that misleading impression. View "Hemphill v. New York" on Justia Law

Plaintiffs, former IBM employees who entered into severance agreements in which they agreed not to join any collective actions against IBM, filed suit challenging the validity of those collective-action waivers, alleging claims under the Age Discrimination in Employment Act of 1967 (ADEA). The district court granted IBM's motion to dismiss for failure to state a claim. In 14 Penn Plaza LLC v. Pyett, 556 U.S. 247 (2009), the Supreme Court held that section 626(f)(1) of the ADEA applied to substantive rights, like the statutory right to be free from workplace age discrimination, but not procedural ones, like the right to seek relief from a court in the first instance.The Second Circuit concluded that collective-action waivers, like arbitration clauses, address procedural, not substantive rights, and thus do not require special disclosures under section 626(f)(1) of the ADEA for their acceptance to be knowing and voluntary. Therefore, the district court correctly held that 14 Penn Plaza governs this case and granted IBM's motion to dismiss. View "Estle v. International Business Machines Corp." on Justia Law

The First Circuit affirmed Defendant's conviction of one count of conspiracy to possess with intent to distribute and to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 846, and one count of possession with intent to distribute 500 grams or more of cocaine, in violation of 21 U.S.C. 841(a)(1), holding that there was no error.Specifically, the First Circuit held (1) the district court did not err in denying Defendant's motion to suppress evidence obtained during a traffic stop and admitting items seized from the vehicle at trial; (2) the district court did not manifestly abuse its discretion in admitting certain statements of lay witnesses; (3) the proceedings did not contravene Defendant's constitutional right to a speedy trial; and (4) Defendant's absence at certain pre-trial proceedings did not violate his statutory or constitutional presence rights. View "United States v. Reyes" on Justia Law

The Supreme Court affirmed Defendant's convictions for multiple counts of first degree murder and sentence of death, holding that no prejudicial error occurred in the proceedings below.After a ten-day trial, a jury found Defendant guilty of the 2012 first degree murders of Penelope Edwards and Troy Dunn under both premeditated and felony murder theories. After the penalty phase of trial, the jury returned death verdicts for both murders. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence recovered during a traffic stop and any fruit of that search; (2) the trial court did not err in the way it conducted voir dire; (3) Defendant's evidentiary challenges were without merit; (4) one instance of prosecutorial error occurred, but the error was not prejudicial; (5) any error during the aggravation phase was harmless; and (6) Defendant's challenges to the death penalty were unavailing. View "State v. Thompson" on Justia Law

In October 2018, Butts County Sheriff’s Office deputies placed signs in the front yards of the residences of all 57 registered sex offenders within the County, warning “STOP” and “NO TRICK-OR-TREAT AT THIS ADDRESS.” The Sheriff also posted an explanation of the signs on Facebook, in order to associate the signs with the registrants who lived on the properties. Before Halloween 2019, three registered sex offenders living in Butts County sued, seeking to enjoin the Sheriff from placing the signs again. Contrary to the Sheriff’s initial assertions, Georgia law does not forbid registered sex offenders from participating in Halloween. The district court rejected the suit on summary judgment.The Eleventh Circuit vacated. The Sheriff’s warning signs are compelled government speech, and their placement violates a homeowner’s First Amendment rights. The forced display of a government message on private property violates the “right to refrain from speaking at all,” and the signs are not a narrowly tailored means of serving a compelling government interest. The Sheriff’s interest in protecting children from sexual abuse is compelling but the Sheriff has not provided any evidence that the registrants actually pose a danger to trick-or-treating children or that these signs would serve to prevent such danger. View "McClendon v. Long" on Justia Law

Lewis left her car parked on an Alsip street during a snowstorm. She was fined $50 for violating an ordinance that prohibits parking on any “primary snow route” if more than one inch has fallen within 12 hours and requires all primary snow routes to be identified by signs; a three-inch limit applies to “all other public streets not designated as primary snow routes.” The street where Lewis had parked was not posted as a primary snow route.Lewis could have challenged the fine in state court but instead filed suit under 42 U.S.C. 1983, alleging that Alsip violated the Due Process Clause by failing to erect signs on every block of every street telling drivers when snow requires them to remove their vehicles. The Seventh Circuit affirmed the dismissal of the suit. The Due Process Clause requires governmental bodies to make laws available to the public, not to ensure that everyone knows all rules. The statute or regulation itself is adequate notice if it is clear. Drivers know that many traffic rules are not set out on signs but still must be obeyed. View "Lewis v. Village of Alsip" on Justia Law