Justia Civil Rights Opinion Summaries

Allen County Officers received an arrest warrant for Gosnell. An anonymous tip indicated that Gosnell was staying at a Fort Wayne motel. The motel manager stated that Gosnell was staying in a room with Jones. Jones had arrests dating back to the 1990s and was listed as a “known resister,” “convicted felon,” and “substance abuser.” At the room, the officers knocked and called out Jones’s street name, stating: “It’s police. We’re not here for you.” Jones said, “She’s not here.” The officers asked Jones to open the door. He requested some time. Both officers estimate that 30-60 seconds elapsed between the first knock and when Jones opened the door. In conversational tones, they reiterated that they were not there for Jones, showed him the warrant, and explained that they would like to “verify” Gosnell was not there. Jones eventually said, “fine,” and moved away from the door. The officers lifted the beds and found a firearm.Jones pled guilty to possessing a firearm as a convicted felon, 18 U.S.C. 922(g)(1) after the denial of his motion to suppress. The Seventh Circuit affirmed the denial of the motion. Jones has not shown that he was seized prior to the search. In light of the totality of the circumstances, a reasonable person in Jones’s position would have felt free to decline the officers’ request to open the door. Jones voluntarily consented to a search of his motel room. View "United States v. Jones" on Justia Law

Hyde, a 26-year-old with bipolar disorder, schizophrenia, and ADHD, took six prescription medications. After his arrest on suspicion of DUI, Hyde submitted to a blood draw. He tested negative for alcohol but positive for amphetamines, consistent with his prescriptions. After several hours without his medications, Hyde charged the door, fell, and injured his head. Hyde emerged from his cell calmly, then sprinted away. He reached a dead end, Officers deployed their Tasers multiple times, then tackled Hyde. After Hyde was in a restraint chair, Pralgo again used his Taser. Callahan-English used her arms to force Hyde’s head into a restraint hold. Minutes later Hyde rolled his head back, gasping for air, as officers passed by. He stopped breathing. Officers tried to revive him. Days later, Hyde died. Hyde’s causes of death included blunt force injuries, kidney damage caused by muscle breakdown, enlarged heart, and coronary artery atherosclerosis.The Ninth Circuit affirmed in part the denial of a motion to dismiss a 42 U.S.C. 1983 suit. Officers Pralgo and Callahan-English used excessive force and violated clearly established law when they used a Taser and put Hyde in a head restraint after Hyde, handcuffed and shackled, posed no threat. Other officers reasonably used force when Hyde resisted. The complaint did not adequately allege that the officers knew of Hyde’s mental health condition or that he was in distress after the altercation; qualified immunity barred the claim that they violated Hyde’s right to adequate medical care. With respect to the failure-to-train and municipal liability claims, the court stated that an inadequate training policy itself cannot be inferred from a single incident. View "Hyde v. City of Wilcox" on Justia Law

The Fifth Circuit affirmed the dismissal of a federal habeas application as time-barred, concluding that petitioner is not entitled to equitable tolling. The court stated that petitioner offers little to no support for his argument that the circumstances in his case are so extraordinary as to necessitate equitable tolling. More importantly, the court concluded that petitioner's plight is entirely self-inflicted and stems from his failure to comply with basic state procedural rules—about which he had notice. Furthermore, in responding to petitioner's initial, unexhausted 28 U.S.C. 2254 application, the State pointed out that petitioner had failed to exhaust his state remedies and that he needed to refile in state court before proceeding to federal court. Therefore, the district court did not err, much less abuse its discretion, in declining to equitably toll the limitations period under the Antiterrorism and Effective Death Penalty Act. The court denied petitioner's motion to appoint counsel as moot. View "Jones v. Lumpkin" on Justia Law

Around midnight, four people were in Shaffers' car, with Shaffers in the driver’s seat, smoking and listening to music while parked. Chicago Police Officers Streeper and Bruno heard loud music coming from the car and smelled marijuana. They blocked Shaffers' car with their car, then approached, identified themselves, and instructed the occupants to put their hands up. Streeper testified that Shaffers initially failed to comply and made “furtive movements with his hands below the [driver’s] seat.” Shaffers fled. Streeper recovered a gun from the floorboard between the driver’s seat and the console. Months later, Shaffers was arrested while appearing in state court for a traffic infraction.Shaffers was charged as a felon in possession of a firearm, 18 U.S.C. 922(g)(1). Denying Shaffers’ motion to suppress, the court concluded that the officers’ approach was a seizure because Shaffers could not move his car and a reasonable person would not have felt free to leave but that the seizure was permissible under "Terry" because the officers had reasonable suspicion. After a mistrial, obstruction of justice charges were added based on Shaffers’ attempts to influence witness testimony. The Seventh Circuit upheld his convictions, rejecting arguments that the gun should have been suppressed; that Shaffers’ Confrontation Clause rights were violated by admitting a witness’s grand jury testimony, that the evidence was insufficient to support his conviction; and that his prior aggravated assault conviction was improperly considered a “crime of violence” at sentencing. View "United States v. Shaffers" on Justia Law

Georgia law places restrictions on which prospective candidates for elective office can appear on the general election ballot. The Libertarian Party of Georgia, prospective Libertarian candidates, and affiliated voters ask the court to hold that Georgia's ballot-access laws unconstitutionally burden their First and Fourteenth Amendment rights and deny them equal protection.The Eleventh Circuit concluded that the district court incorrectly held that the laws violate their First and Fourteenth Amendment rights. The court explained that, under the Anderson framework, the laws need only be justified by the State's important regulatory interests. In this case, the interests the Secretary asserts—in requiring some preliminary showing of a significant modicum of support before printing the name of a political organization's candidate on the ballot, in maintaining the orderly administration of elections, and in avoiding confusion, deception, and even frustration of the democratic process at the general election—are compelling. The court agreed with the district court's conclusion that Georgia's laws do not cause an equal protection violation. The court concluded that the Secretary's stated interest sufficiently justifies the distinction between candidates. Accordingly, the court reversed in part, affirmed in part, vacated the district court's injunction, and remanded. View "Cowen v. Secretary of State of the State of Georgia" on Justia Law

The Supreme Court reversed the order of the district court affirming the denial of Defendant's motion to suppress evidence, holding that law enforcement officers lacked particularized suspicion to justify their investigatory stop of Defendant.Defendant was stopped by law enforcement officers based solely on his "flicking" his high beams on and off once. Defendant entered a conditional guilty plea to aggravated driving under the influence, third offense, reserving the right to appeal the justice court's denial of his motion to suppress. The district court affirmed. The Supreme Court reversed, holding that the totality of the circumstances did not give rise to particularized suspicion, and therefore, the seizure violated Defendant's constitutional right to be free from unreasonable searches and seizures. View "State v. Gardner" on Justia Law

The Supreme Court reversed Defendant's conviction of illegal possession of ammunition, holding that the district court erred by denying Defendant's motion to suppress.During a traffic stop, law enforcement officers questioned Defendant, who was a passenger in the stopped vehicle, regarding the conditions of his pretrial release. After Defendant was arrested for violating a condition of his pretrial release, a pat-down search revealed ammunition in Defendant's pocket. Defendant filed a motion to suppress, arguing that the officer’s questions about the conditions of his pretrial release improperly expanded the scope of the traffic stop. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) violation of a condition of pretrial release does not constitute criminal activity allowing a law enforcement officer to expand the scope of a traffic stop; and (2) the officer's questioning of Defendant about the conditions of his pretrial release exceeded the permissible scope of a traffic stop. View "State v. Sargent" on Justia Law

Greene was booked into the Crawford County Jail after having his bond revoked for attending a plea hearing while intoxicated. Over the next four days, Greene began hallucinating and exhibiting other symptoms of delirium tremens, a life-threatening complication of alcohol withdrawal that the Sixth Circuit has recognized as an objectively serious medical need. Greene ultimately suffered acute respiratory failure. He died four days later. Crawford County officials did not provide any medical care to Greene before his incapacitation but only sought a mental health evaluation from a Community Mental Health Authority and purportedly relied on that evaluation in deciding not to seek medical assistance.In a suit under 42 U.S.C. 1983, claiming deliberate indifference to Greene’s medical need and that Crawford County is liable for maintaining an unconstitutional policy of not providing medical care to inmates suffering from delirium tremens, the district court denied qualified immunity at summary judgment to some county officials and denied Crawford County summary judgment. The Sixth Circuit affirmed that the officials were not entitled to qualified immunity. Greene experienced a clearly established life-threatening medical condition for at least two days. The defendants did not provide any medical assistance during that time. The court dismissed Crawford County’s interlocutory appeal for lack of appellate jurisdiction. View "Greene v. Crawford County" on Justia Law

Booker is on Florida’s death row for first-degree murder. In 2012, the Eleventh Circuit affirmed the denial of federal habeas relief. In 2020, the Capital Habeas Unit of the Office of the Federal Public Defender (CHU) sought permission to represent Booker in state court to exhaust a “Brady” claim so that Booker could pursue the claim in a successive federal habeas petition. The Brady claim focused on the prosecution’s failure to disclose notes that allegedly could have been used to impeach an FBI hair expert. Booker said that he had learned through a FOIA request and a review by a qualified microscopist that there were inconsistencies between the expert’s trial testimony and his notes. The state objected to the appointment of CHU, noting that Booker had a state-law right to counsel through Florida’s Capital Collateral Regional Counsel North (CCRC-N); CCRC-N counsel was appointed to represent Booker in state court. Nonetheless, the district court appointed CHU under 18 U.S.C. 3599 to represent Booker in state courtThe Eleventh Circuit dismissed an appeal. Florida cannot establish standing based on a hypothetical conflict of interest that is not actual or imminent. State courts are empowered to reject appearances by CHU counsel, so the appointment cannot have inflicted an injury on Florida’s sovereignty. View "Booker v. Secretary, Florida Department of Corrections" on Justia Law

The Supreme Court affirmed Defendant's convictions for first degree murder and other crimes and Defendant's death sentence, holding that any found or assumed errors were individually harmless and that there was no cumulation of error that merited reversal.Specifically, the Supreme Court found or assumed errors in the admission of prior crimes evidence, a prosecutorial misconduct claim concerning a jury argument that Defendant signed a parole form advising him of a possible life sentence, a claim that the defense was prevented from responding to the prosecutor's argument, a claim that certain expert testimony usurped the trial court's role to instruct the jury about the law, and four additional prosecutorial misconduct claims. The Court held (1) any assumed or actual error in each of these claims was individually harmless; and (2) there was no cumulative error warranting reversal. View "People v. Johnson" on Justia Law