Justia Civil Rights Opinion Summaries

Texas Senate Bill 8, the 2021 Heartbeat Act, prohibits physicians from performing or inducing an abortion if the physician detected a fetal heartbeat. S.B. 8 does not allow state officials to enforce the law but directs enforcement through “private civil actions” seeking injunctions and damages awards against those who perform or assist with prohibited abortions. Abortion providers may defend themselves by showing that holding them liable would place an “undue burden” on women seeking abortions.Abortion providers (petitioners) sought pre-enforcement review of S.B. 8 and an injunction barring its enforcement. They sought to certify a class and request an order enjoining all state-court clerks from docketing S.B. 8 cases, and all state-court judges from hearing them. The district court denied motions to dismiss. The Fifth Circuit denied a request for an injunction barring enforcement pending appeal. The petitioners sought injunctive relief in the Supreme Court, which concluded that the filings failed to identify a basis for disturbing the Fifth Circuit’s decision.On certiorari, the Court held that a pre-enforcement challenge to S.B. 8 under the U.S. Constitution may proceed against certain defendants but not others, without addressing whether S.B. 8 is consistent with the Constitution.The Eleventh Amendment and sovereign immunity do not allow an action to prevent state-court clerks and judges from enforcing state laws that are contrary to federal law. No Article III “case or controversy” between “adverse litigants” exists between the petitioners and either the clerks or judges. Texas Attorney General Paxton should be dismissed as possessing no enforcement authority in connection with S.B. 8. Even if Paxton had enforcement power, a federal court cannot parlay that authority into an injunction against any unnamed private parties who might pursue S.B. 8 suits. No court may “enjoin the world at large” or purport to enjoin challenged “laws themselves.” Sovereign immunity does not shield executive licensing officials who may take action against the petitioners for violations of Texas’s Health and Safety Code, including S.B. 8. A single private party, Dickson, should be dismissed, given his sworn declarations that he has no intention to file an S.B. 8 suit. View "Whole Woman's Health v. Jackson" on Justia Law

The Supreme Court affirmed Defendant's sentence of life imprisonment with no chance of parole for fifty years but vacated the district court's order imposing lifetime postrelease supervision and electronic monitoring as a condition of parole, holding that those components of Defendant's sentence were illegal.Defendant pleaded no contest to premeditated first-degree murder. The district court denied Defendant's request to depart from his presumptive hard fifty sentence and to instead sentence him to a hard twenty-five sentence. The court then imposed lifetime postrelease supervision and electronic monitoring as a condition of his parole. The Supreme Court affirmed Defendant's hard fifty sentence, holding that the district court (1) did not err in denying Defendant's departure motion; but (2) lacked authority to impose lifetime postrelease or electronic monitoring parole conditions. View "State v. Boswell" on Justia Law

The Supreme Court reversed in part the judgment of the trial court finding Defendant guilty of manslaughter in the first degree with a firearm and other offenses, holding that the trial court improperly admitted certain evidence.On appeal, Defendant argued that his statements to the police were improperly admitted into evidence because his constitutional rights were violated when the police continued to question him after he invoked his right to counsel pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Defendant further argued that the prosecutor committed improprieties during closing argument, depriving him of his right to a fair trial. The Supreme Court affirmed, holding (1) the admission of Defendant's written statement and a portion of a video recording of the interview with police should have been suppressed, and the error was not harmless as to Defendant's conviction of manslaughter in the first degree with a firearm; and (2) there was no other reversible error in this case. View "State v. Culbreath" on Justia Law

Plaintiffs filed two actions against their landlord, MAA, alleging that it charged unreasonable late fees in violation of the Texas Property Code and seeking to certify a class under Rule 23 of the Federal Rules of Civil Procedure. The district court certified in both cases and MAA sought interlocutory review of class certification.The Fifth Circuit concluded that, under section 92.019 of the Texas Property Code, there is no requirement that a landlord engage in a process to arrive at its late fee so long as the fee is a reasonable estimate at the time of contracting of damages that are incapable of precise calculation. Therefore, the district court erred in interpreting section 92.019 and the court remanded to the district court to determine if class certification is appropriate. View "Cleven v. Mid-America Apartment Communities, Inc." on Justia Law

Spokane Public Library hosted a children’s event called “Drag Queen Story Hour.” Because the event proved controversial, police separated 150 protesters and 300 counterprotesters into separate zones near the library. Yaghtin arrived at the event wearing a press badge and identified himself as a member of the press. Yaghtin alleges he was assigned a police “detail” to accompany him through a crowd of counterprotesters out of concern that he was “fake press.” While walking through the counterprotest zone, Yaghtin began speaking with a counterprotester, who asked him whether he was the person that had advocated for the execution of gay people. Officer Doe interrupted the exchange, and escorted Yaghtin through the counterprotest zone. Affirming the dismissal of a suit under 42 U.S.C. 1983, the Ninth Circuit held that Doe was entitled to qualified immunity. The plaintiffs did not challenge the ordinance or permit scheme, nor the police department’s use of separate protest zones. No precedent would have alerted Doe that his enforcement would violate clearly established First Amendment law; it was not unreasonable for Doe to believe that it was lawful for him to examine the substance of Yaghtin’s speech to enforce the separate protest zone policy. The city cannot be held liable because nothing in the complaint plausibly alleged a policy, custom, or practice leading to any violation. Plaintiffs’ allegations amounted to only an “isolated or sporadic incident” that could not form the basis of liability under “Monell.” View "Saved Magazine v. Spokane Police Department’" on Justia Law

The Supreme Court dismissed the circuit court's dismissal of Plaintiff's lawsuit against the Arkansas Department of Finance and Administration, Arkansas Alcoholic Beverage Control Division, Arkansas Medical Marijuana Commission (collectively, State Defendants) and Nature's Herbs and Wellness of Arkansas, LLC, holding that the Court lacked jurisdiction.Plaintiff brought this suit alleging violations of the Arkansas Medical Marijuana Commission's administrative rules, the Administrative Procedure Act, and Plaintiff's equal protection and due process rights. The circuit court concluded that Plaintiff lacked standing to bring its lawsuit and dismissed the complaint. The Supreme Court dismissed Plaintiff's appeal, holding that because the record was not filed within ninety days from the filing of the first notice of appeal this Court lacked jurisdiction over the appeal. View "Medicanna, LLC v. Arkansas Department of Finance & Administration" on Justia Law

Arizona voters may vote by mail during the last four weeks of an election. The voter must sign an affidavit that is printed on a specially provided, postage-paid envelope. A ballot with a missing signature cannot be counted. On September 10, 2020, weeks before the upcoming presidential election, the district court enjoined the enforcement of Ariz. Stat. 16-548(A), which requires early voters to have signed their ballots by 7:00 PM on Election Day in order to have their votes counted. The Ninth Circuit granted emergency motions and stayed the injunction, pending appeal.In 2021, the Ninth Circuit entered a permanent stay. The state has shown a likelihood of success on the merits. Arizona's signature deadline imposes, at most, a "minimal" burden on those who seek to exercise their right to vote. The state made a strong showing that its deadline reasonably advances important regulatory interests in reducing the burden on poll workers, especially during the days immediately following an election. The public interest is served by preserving Arizona's existing election laws. Although Arizona’s law implicated national interests, at least when the election included presidential candidates, that factor alone did not mean that strict scrutiny must apply. The court noted that the Arizona legislature “laudably amended its election code in 2019 to allow voters an extended period to correct mismatched signatures." Arizona’s decision not to grant the same extension to voters who neglect to sign the affidavit passed constitutional muster. View "Arizona Democratic Party v. Hobbs" on Justia Law

The Estate of Willy Fritz filed suit against a police officer and the City of West Union, alleging a claim of recklessness, among other things, after the officer's police cruiser crashed into Fritz's truck which led to Fritz's death. The district court granted defendants' motion for summary judgment.The Eighth Circuit affirmed, concluding that the evidence does not establish recklessness under Iowa law where it failed to show that the officer had conscious knowledge of a dangerous situation as his police cruiser crossed a four-way intersection. In this case, the police cruiser approached the intersection, traffic had stopped, the road was straight, and the "lane ahead" was clear. Therefore, the district court did not err in granting summary judgment. View "Estate of Fritz v. Henningar" on Justia Law

After an explosion at Massey’s West Virginia coal mine killed 29 miners, Blankenship, then Massey’s Chairman of the Board and CEO, was convicted of conspiring to willfully violate federal mine safety and health standards, 30 U.S.C. 820(d) and 18 U.S.C. 371. The evidence indicated that Blankenship had willfully failed to address numerous notices of mine safety violations that Massey had received, favoring production and profits over safety. Following the trial and in response to Blankenship’s ongoing requests, the government produced documents to Blankenship that it had not produced before trial and that it should have produced under applicable Department of Justice policies. The suppressed documents fell broadly into two categories: memoranda of interviews conducted of seven Massey employees and internal emails and documents of the Mine Safety and Health Administration (MSHA) showing, among other things, some MSHA employees’ hostility to Massey and Blankenship.The Fourth Circuit affirmed the denial of Blankenship’s 28 U.S.C. 2255 motion to vacate his conviction. While the documents were improperly suppressed, they were not material in that there was not a reasonable probability that they would have produced a different result had they been disclosed before trial. The verdict that Blankenship conspired to willfully violate mandatory mine standards was supported by ample evidence. View "United States v. Blankenship" on Justia Law

The Fifth Circuit affirmed the district court's grant of the Department's motion for judgment on the pleadings, holding that Louisiana has not waived its sovereign immunity for claims under Title I of the Americans with Disabilities Act. In this case, plaintiff filed suit for disability discrimination under the Act after he was terminated from his job of nearly twenty-four years based on his medical problems. The court also denied plaintiff's request to certify a question to the Louisiana Supreme Court, concluding that this case does not present a genuinely unsettled matter of Louisiana law and thus certification is not appropriate. View "Fletcher v. Louisiana Department of Transportation and Development" on Justia Law