Justia Civil Rights Opinion Summaries

The Supreme Court held that the West Virginia Wiretapping and Electronic Surveillance Act (West Virginia Act), W. Va. Code 62-1D-1 through 16, runs afoul of the First Amendment to the federal Constitution and W. Va. Const. art. III, 7 and is unconstitutional as appleid to the extent that it allows a civil action to be maintained against an innocent third party who publishes information of public concern that was obtained by the unlawful interception of wire, oral, or electronic communication in violation of the statute but who did not participate in the unlawful interception of the communication.Petitioners, public school employees, alleged that the mother of A.P., a special education student in their classroom, violated both the West Virginia Act and its federal construct by placing a secret audio recording device in A.P.'s hair, purporting to show Petitioners physically and verbally abusing students. After Petitioners resigned, they brought this complaint alleging that Respondents, various media groups or outlets, violated the West Virginia Act by using and disclosing Petitioners' intercepted communications. The circuit court granted Respondents' motions to dismiss. The Supreme Court affirmed, holding that the circuit court did not err in dismissing the case. View "Yurish v. Sinclair Broadcast Group, Inc." on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, criminal attempt to commit robbery in the first degree, conspiracy to commit robbery in the first degree, and criminal possession of a firearm, holding that the trial court did not err in denying Defendant's motions to suppress.In his suppression motions, Defendant sought to suppress (1) the firearm and related evidence seized from his residence, which evidence he argued was discovered as a result of an unlawful search, and (2) the incriminating statements he made during an interrogation at the police station, claiming the statements were made involuntarily. The Supreme Court affirmed the denial of Defendant's motions to suppress, holding (1) the trial court properly Defendant's motion to suppress the evidence obtained during the search of his residence; and (2) Defendant's statements were voluntary, and the trial court properly admitted them into evidence at trial. View "State v. Griffin" on Justia Law

Elhady, a U.S. citizen returning from Canada, was detained for questioning by border-patrol agents. They took Elhady’s jacket and shoes, leaving him only his shirt, pants, undergarments, and socks. According to Elhady, the cell “got colder and colder,” and he began shivering uncontrollably. He says he yelled to the officers but they told him, “you’ll be out soon.” After about four hours, the officers told him he could leave. He stated he felt too ill to drive. The officers called an ambulance. The EMT noted that Elhady received the highest score on a test that measured his level of consciousness; he had delayed capillary refill, consistent with exposure to the cold. When he reached the hospital, his temperature was 96.08 degrees, barely below the normal range. The physician let him rest. When Elhady woke up, the doctor told him he was “good to go.” Elhady sued several border-patrol officers, seeking monetary damages under “Bivens.”The district court found that extending Bivens to provide an implied cause of action here was appropriate and found enough evidence to show that one officer, Bradley, had violated Elhady’s right to be “free from exposure to severe weather and temperatures,” which was clearly established so that qualified immunity did not protect Bradley. The Sixth Circuit reversed. The district court erred in engaging in the “disfavored judicial activity” of recognizing a new Bivens action. National security is a special factor counseling against extending Bivens to the border context. View "Elhady v. Unidentified CBP Agents" on Justia Law

The Eleventh Circuit reversed the district court's grant of summary judgment in favor of a police officer individually and the City of Miami Beach on plaintiff's claims of excessive force and state law battery. Plaintiff alleged that his arrest was effected and he was fully secured, not resisting, and not posing a threat when the officer gratuitously and forcibly struck him in his face.The court reviewed the evidence and videos in the light most favorable to plaintiff, and with the benefit of oral argument, concluding that the district court erred in granting summary judgment in favor of defendants. In this case, a reasonable jury could find that the officer used excessive force in violation of the Fourth Amendment when he entered the holding cell and forcibly struck plaintiff, who was then secure, not resisting, and not a safety threat to any officers. Furthermore, an objectively reasonable officer would have known at the time that it was clearly unlawful to gratuitously and forcibly strike an arrestee who was fully secured, not resisting, not posing a safety threat, and not attempting to flee. Likewise, summary judgment is not warranted on plaintiff's state law battery claims. The court remanded for further proceedings. View "Johnson v. City of Miami Beach" on Justia Law

Plaintiff filed suit challenging the constitutionality of Section 3-506 of Maryland's Election Law, which provides that a list of Maryland registered voters (the List) may be given to an applicant who is himself a registered Maryland voter (Access Provision), so long as the applicant attests that he will use the List for purposes that are related to the electoral process (the Use Provision). On remand from the Fourth Circuit, the district court awarded summary judgment to Maryland state officials on plaintiff's Use Provision-based free speech and vagueness claims.The Fourth Circuit applied the Anderson-Burdick balancing test and concluded that plaintiff's claim that — as applied to him — the Use Provision contravenes the Free Speech Clause was without merit. The court explained that, when weighed against the State's interests — that is, safeguarding the List, protecting Maryland's election system, and shielding Maryland registered voters from harassment — the burden imposed on plaintiff is modest. The court also found plaintiff's as-applied vagueness claim unavailing where plaintiff understands the Use Provision's reach. Finally, the court found meritless plaintiff's facial challenges to the Use Provision which argued that the Use Provision facially contravenes the Free Speech Clause and that the phrase "related to the electoral process" is facially vague. Accordingly, the court affirmed the district court's judgment. View "Fusaro v. Howard" on Justia Law

Garrett, a New Jersey prisoner, has commenced at least 10 civil actions against prison officials, state officials, and the United States, avoiding paying filing fees for these lawsuits by proceeding in forma pauperis. All his lawsuits have been unsuccessful. Garrett appealed the dismissal of his latest lawsuit, which concerns his risk of contracting COVID-19 and speedy trial issues.The Third Circuit affirmed, citing the three-strikes rule, 28 U.S.C. 1915(g). Noting the division among circuit courts, the court stated that a suit dismissed under “Heck” is dismissed for failure to state a claim and counts as a strike. In Heck, the Supreme Court held that a prisoner lacks a “cause of action” under section 1983 if the prisoner is challenging an “allegedly unconstitutional conviction or imprisonment” before having the conviction or sentence overturned (the favorable-termination requirement). Garrett has three prior suits dismissed for failure to meet Heck’s “favorable-termination” requirement. Garrett has not shown that he is “under imminent danger of serious physical injury,” 28 U.S.C. 1915(g). View "Garrett v. Murphy" on Justia Law

The Supreme Court affirmed Defendant's conviction of first degree sexual assault of a child, holding that there was no merit to Defendant's claims of trial error, and Defendant was not entitled to relief on his claims of ineffective assistance of counsel.On appeal, Defendant argued (1) the trial court erred by, inter alia, refusing to appoint him a DNA expert and by sustaining the prosecution's objection to further use of a forensic video to refresh the victim's recollection; and (2) trial counsel provided ineffective assistance in numerous ways. The Supreme Court affirmed, holding (1) Defendant's claims of trial error were without merit; and (2) all of Defendant's claims of ineffective assistance of counsel were without merit with the exception that this Court did not reach the merits of one of Defendant's ineffective assistance arguments. View "State v. Wood" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual abuse of a child, his granddaughter, holding that the district court erred by excluding evidence that another person, a teenager who testified for the State, sexually abused the victim.On appeal, Defendant argued (1) the Supreme Court should overrule State v. Pearson, 514 N.W.2d 452 (Iowa 1994), which would result in the reversal of his conviction; and (2) the district court erred in applying the "constitutional rights" exception to the rape shield law, Iowa R. Evid. 5.412(b)(1)(C). The Supreme Court reversed, holding (1) this Court declines to overrule Pearson; and (2) excluding Defendant's cross-examination of his granddaughter and the teenager about their relationship violated Defendant's rights under the Confrontation and Due Process Clauses and the constitutional rights exception to the rape shield law. View "State v. Montgomery" on Justia Law

Plaintiff filed suit against Defendants Galman, Sutton, and the City of New Orleans, alleging a violation of his constitutional rights under 42 U.S.C. 1983, as well as various state law claims including assault, battery, and false arrest. Plaintiff also alleged a section 1983 claim against the City for failure to hire, train, supervise, or discipline officers, as well as various state law claims including negligent hiring, negligent supervision and retention, and vicarious liability. Plaintiff's claims stemmed from Galman and Sutton's actions harassing plaintiff while he was sitting at a local bar in his military fatigues and beating plaintiff unconscious. Galman and Sutton were local police officers who were off duty. The district court dismissed plaintiff's federal claims because it found that the officers were not acting under color of law.The Fifth Circuit concluded that plaintiff alleged sufficient facts to support all of his claims where plaintiff has adequately pleaded facts which establish that Galman and Sutton acted under color of law. In this case, plaintiff alleges that when he exited the bar, Sutton acted as a police officer and gave plaintiff a direct order to stop and not leave the patio area of the bar; plaintiff obeyed; when plaintiff attempted to drive away after getting violently beaten, Sutton and Galman ordered him to stop and to step out of his vehicle; and, because they acted like police officers, plaintiff believed he was not free to leave, and did as he was ordered. However, the court concluded that plaintiff does not allege sufficient facts to support a Monell claim against the City based on the officers' actions. The court further concluded that plaintiff has pleaded sufficient facts to support his state-law negligent hiring, retention, and supervision claims against the City. Finally, the district court correctly dismissed the vicarious liability claim against the City. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Gomez v. Galman" on Justia Law

Reinebold, then 56 years old, applied to be the head baseball coach of Indiana University South Bend (IUSB). After IUSB declined to hire Reinebold, he sued IUSB, Athletic Director Bruce, and Assistant Athletic Director Norris under the Age Discrimination in Employment Act (ADEA) and 42 U.S.C. 1983. The district court dismissed all of Reinebold’s claims with his concession except for his section 1983 claims against Bruce and Norris in their individual capacities. The district court then entered summary judgment in favor of Bruce and Norris, finding that Reinebold did not identify a suitable comparator and did not show that he was intentionally treated differently because of his age.The Seventh Circuit affirmed. The hiring committee distinguished Reinebold and his proposed comparator Buysse (age 31) based on their respective performances during their interviews. The evidence shows that Reinebold performed poorly during his phone interview. Buysse performed well. An employer is not required to score a job interview using objective criteria. View "Reinebold v. Bruce" on Justia Law