Justia Civil Rights Opinion Summaries

Plaintiff, an inmate at Mule Creek State Prison, asserted that he was physically and sexually assaulted in March 2016 and filed a grievance in March 2016, which prison officials failed to process. He submitted a second grievance in May 2016 concerning subsequent events, but referring to the March assaults. The district court reasoned that because the March assaults were mentioned in the May grievance which was pending when the plaintiff filed his 42 U.S.C. 1983 action, an avenue of administrative relief remained open and the plaintiff could not be excused from exhausting the March grievance.The Ninth Circuit reversed, in part, the dismissal of the suit. The prison’s failure to respond to the March grievance rendered the administrative appeals process “unavailable” under the Prison Litigation Reform Act, 42 U.S.C. 1997e. Where inmates take reasonably appropriate steps to exhaust but are precluded from doing so by a prison’s erroneous failure to process the grievance, the exhaustion requirement is satisfied. A later-filed grievance that alleges new complaints but refers to a previous, already exhausted grievance for context does not render the first grievance unexhausted. Because the May grievance was still pending when the complaint was filed, the district court properly deemed that grievance unexhausted. View "Fordley v. Lizarraga" on Justia Law

The Supreme Court approved the decision of the First District Court of Appeal in this case, holding that Fla. Stat. 942.051(3), which prohibits raising an unpreserved claim of error on direct appeal absent a showing of fundamental error, precludes appellate review of unpreserved claims of ineffective assistance of trial counsel on direct appeal.Defendant was found guilty of first-degree murder. On appeal, Defendant argued that he received ineffective assistance of counsel. The First District affirmed Defendant's convictions and sentence and declined to address his claims of ineffective assistance because he did not preserve any of the errors he advanced on appeal and did not make a claim of fundamental error. The Supreme Court approved of the decision below, holding that the plain text of section 924.051 prohibits raising unpreserved error on direct appeal absent a showing of fundamental error. View "Steiger v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant's arguments on appeal were unavailing.Specifically, the Supreme Court held that the trial court did not abuse its discretion in granting Defendant's request for self-representation because (1) a competency hearing was not required; (2) substantial evidence supported the findings that Defendant's waiver of the right to counsel was knowing, voluntary, and intelligent under Faretta v. California, 422 U.S. 806; and (3) the trial court was not required to find that Defendant suffered from severe mental illness to the point that he was incompetent to conduct trial proceedings by himself. View "Noetzel v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony sexual intercourse without consent, holding that Defendant received constitutionally effective assistance of counsel.At issue was whether Defendant's trial counsel rendered ineffective assistance when counsel allowed prior consistent statements from a forensic interview into evidence without challenge. The Supreme Court affirmed, holding (1) the record before the Court implied at least a plausible justification for counsel's actions; and (2) without more evidence, it cannot be determined whether defense counsel did not perform effectively for Defendant. View "State v. Mikesell" on Justia Law

Michigan Department of Corrections inmates may hold formal group services or possess certain religious property only if the Department has formally recognized their faith. Though the Department recognizes the Ifa faith, it is one of only three recognized religions that was denied group services. A group is not guaranteed religious services if there are less than five prisoners within the same security level in a facility; the Department may bar group services if they may pose “safety and security” concerns. When an inmate submits a request for group worship or religious property, the warden must forward the request to the Special Activities Coordinator, who must evaluate the request. The deputy director makes the final decision. Discretion is minimal.Between his conversion to the Ifa faith in August 2015 and filing this lawsuit more than two years later, Byrd sent four requests for Ifa group services and nine items that he considers essential to his faith (a straw prayer mat, herbs, and beads). Although Byrd enlisted the chaplain’s assistance, none of his requests received a response. Byrd sued, alleging violations of his rights under the Religious Land Use and Institutionalized Persons Act, the Free Exercise Clause, and the Equal Protection Clause. The Sixth Circuit reversed the dismissal of the suit. The district court erred in viewing the problem as procedural; the long delay is tantamount to a substantive denial. View "Byrd v. Haas" on Justia Law

Wesson was charged with murdering 81-year-old Varhola and attacking (and nearly killing) his 77-year-old wife, after they invited him into their home on February 25, 2008. A three-judge panel convicted Wesson of several charges, including two counts of aggravated murder, and imposed the death penalty. Wesson unsuccessfully sought to suppress his confession to police due to his alleged intoxication and other factors when they questioned him. On direct appeal, the Ohio Supreme Court vacated one of Wesson’s aggravated murder convictions but affirmed his remaining convictions and the death sentence; the court rejected Wesson’s claim that his alleged intoxication vitiated his Miranda waiver.Wesson sought relief under 28 U.S.C. 2254, alleging that he is intellectually disabled and therefore ineligible for the death penalty under Atkins v. Virginia, and the government violated his right against self-incrimination when it introduced his post-Miranda statement. The district court found that Wesson made a credible claim of intellectual disability and dismissed that claim and a related ineffective-assistance-of-counsel claim without prejudice to allow the state court to conduct an evidentiary hearing. The Sixth Circuit affirmed the denial of relief on Wesson’s second claim. The state courts did not unreasonably apply the law or facts with respect to his confession, which occurred when he allegedly was intoxicated. View "Wesson v. Shoop" on Justia Law

As students were arriving at the high school, an administrator reported an unknown man (Coleman, age 39) “asleep or passed out” in his vehicle with a crossbow visible in the backseat. The vehicle, stopped but running, was primarily parked in a travel lane. Deputy Johnson believed possession of the crossbow was illegal under Virginia law because it could fire “a projected missile on the school campus.” During questioning, Coleman stated that he had a firearm in the vehicle’s center console. Johnson asked Coleman to exit the vehicle. When Coleman did so, Johnson observed “a fairly large bag of a green leafy substance that appeared to be marijuana” beside the driver’s seat. Another deputy searched the vehicle, finding marijuana, crystal methamphetamine, individual baggies, a scale, a .38 Special revolver, and the crossbow.Coleman was among 28 defendants indicted for participating in a drug trafficking organization. Coleman was charged in two drug counts and for using and carrying a firearm during and in relation to a drug trafficking crime. Coleman unsuccessfully moved to suppress the evidence, arguing that Johnson did not have reasonable suspicion of criminal activity to conduct an investigative “Terry” stop because possession of a crossbow on school grounds is not illegal in Virginia. The Fourth Circuit affirmed his convictions and 211-month sentence. Even if Coleman had not possessed the crossbow, Johnson would have had reasonable suspicion to conduct an investigative stop based on the totality of the circumstances. View "United States v. Coleman" on Justia Law

Shortly after midnight, Suffolk County police officers went to Torcivia’s home in response to what was described as a violent domestic incident, after Torcivia’s daughter called an emergency child protection hotline. The officers determined that Torcivia, who admittedly had been drinking, needed to be transported to a state-run mental health facility for evaluation. While he was at the facility, the officers seized his firearms from his home pending further investigation. Torcivia argues that in doing so, the officers acted pursuant to an official county policy or custom that violated the Fourth Amendment, making the county subject to “Monell” liability.The Second Circuit affirmed the dismissal of Torcivia’s 42 U.S.C. 1983 claims. Although the evidence permitted a reasonable jury to find that it was a “standard procedure” for county officers to temporarily take action to “safeguard weapons until whatever investigation is done” if “there is a domestic incident and somebody is transported to CPEP,” the county is not liable under Monell. The policy falls within the “special needs” exception to the Fourth Amendment’s warrant requirement; under these circumstances, the county’s policy did not cause a violation of Torcivia’s Fourth Amendment rights. Employees of the state-run mental health facility were entitled to qualified immunity under federal and New York law for claims related to their alleged failure to discharge Torcivia promptly. View "Torcivia v. Suffolk County, New York" on Justia Law

The Supreme Court held that neither a showing of exigent circumstances nor a showing of the impracticability of obtaining an arrest warrant is necessary to sustain the constitutionality of a warrantless arrest under either the Ohio Constitution or the United States Constitution.Defendant was convicted of multiple drug offenses. On appeal, Defendant challenged the trial court's denial of his motion to suppress, arguing that his arrest was unlawful because there were no exigent circumstances to justify a warrantless arrest. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a warrantless arrest based on probable cause and conducted in public is reasonable under the Fourth Amendment; (2) neither exigent circumstances nor the impracticability of obtaining a warrant is required to justify a warrantless felony arrest that is supported by probable cause and that is conducted in public; and (3) the arrest in this case was constitutionally valid. View "State v. Jordan" on Justia Law

A wardship petition charged Y.C., then 17 years old, with assault with a firearm, carrying a loaded firearm, and possession of a firearm by a minor. Y.C. allegedly shot a suspected rival gang member in the leg. Arrested, Y.C. was taken to the Juvenile Assessment Center, where he met with a probation officer and invoked his Miranda rights. Y.C. agreed to participate in a mental health assessment conducted by a family therapist, pursuant to an established protocol of the Juvenile Services Division of the San Mateo County Probation Department. The therapist provided a summary of her interview to the probation department, which included the summary in a report provided to the juvenile court at Y.C.’s detention hearings.The court of appeal dismissed Y.C.’s writ petition as moot to the extent that it sought relief relating to his detention During the pendency of the proceeding, Y.C. entered a change of plea and was released from detention. The court otherwise denied the petition, rejecting arguments that the disclosure of the assessment interview to the probation department and juvenile court, and its use at his detention hearings, violated his constitutional right against self-incrimination and his right to counsel, as well as HIPAA and California’s Confidentiality of Medical Information Act. View "Y.C. v. Superior Court" on Justia Law