Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the district court affirming Defendant's license suspension, holding that law enforcement officers did not deprive Defendant of his right to an independent chemical test of his blood alcohol content, and therefore, his statutory and due process rights were not violated.Defendant was arrested for driving while under the influence of alcohol. Defendant submitted to a chemical breath test, which indicated that his blood alcohol concentration exceeded the legal limit. Defendant was advised of his right to obtain an independent chemical test at his own expense, and Defendant chose to exercise it. Defendant, however, never obtained the test. The Wyoming Department of Transportation suspended Defendant's driver's license for ninety days. Both the Office of Administrative Hearings and district court upheld the suspension. The Supreme Court affirmed, holding (1) substantial evidence supported the finding that law enforcement officers did not interfere with Defendant's right to obtain an independent blood test; and (2) the relevant statutes and substantive due process did not require law enforcement officers to do more than allow Defendant to go to the nearest hospital or clinic to obtain a test. View "Johnson v. State ex rel., Wyoming Department of Transportation" on Justia Law

Wood served time in Indiana state prison for methamphetamine‐related offenses. He was released on parole, subject to conditions, including that he was subject to "reasonable" searches, Wood violated his parole by failing to report to his supervising officer. The Parole Board issued an arrest warrant. Agents arrested Wood at his home. Agent Gentry secured Wood with wrist restraints, conducted a frisk search, and noticed Wood repeatedly turning toward his cellphone, which was lying nearby. Gentry picked up the cellphone and handed it to Agent Rains. Wood demanded that his cellphone be turned off and began to physically resist Gentry. Rains felt something “lumpy” on the back of Wood’s cellphone, removed the back cover, and found a packet of a substance which Rains believed to be methamphetamine. Wood admitted the substance was methamphetamine. A later search of the home revealed syringes and other drug paraphernalia.Seven days after Wood’s arrest, an Indiana Department of Correction investigator performed a warrantless search of Wood’s cellphone, which revealed child pornography. The investigator forwarded the information to the FBI, which obtained a search‐and‐seizure warrant for Wood’s cellphone and its contents. Charged under 18 U.S.C. 2252(a)(2), (a)(4)(B), Wood unsuccessfully moved to suppress the data extracted from his cellphone. The Seventh Circuit affirmed. Given Wood’s diminished expectation of privacy and Indiana’s strong governmental interests, the search of Wood’s cellphone was reasonable. View "United States v. Wood" on Justia Law

The Supreme Court reversed the order of the circuit court reversing the determination of an Arkansas Department of Human Services (DHS) administrative law judge (ALJ) that allegations of child maltreatment made against Steven Mitchell were true and that Mitchell should be listed on the Arkansas Child Maltreatment Central Registry, holding that the circuit court erred.In reversing the DHS's determination, the circuit court concluded that the agency decision was based on unlawful procedures and a violation of Mitchell's due process rights. The Supreme Court reversed, holding (1) the DHS's failure to follow its own statutory notice procedures violated Mithcell's statutory rights when DHS placed his name on the maltreatment registry in 2004, but the DHS's earlier failures did not vitiate the 2018 agency decision at issue on review; and (2) substantial evidence supported the DHS's decision, and before the decision was made Mitchell received the required notice, he had an opportunity for a meaningful hearing, and his substantial rights were not prejudiced. View "Arkansas Department of Human Services Crimes Against Children Division v. Mitchell" on Justia Law

The estate of a mentally ill and intellectually disabled prisoner who committed suicide while in Utah Department of Corrections (“UDC”) custody appealed the dismissal of its lawsuit against the UDC. Brock Tucker was seventeen when he was imprisoned at the Central Utah Correctional Facility (“CUCF”). At CUCF, Tucker endured long periods of punitive isolation. CUCF officials rarely let him out of his cell, and he was often denied recreation, exercise equipment, media, commissary, visitation, and library privileges. Tucker hanged himself approximately two years after his arrival at CUCF. Plaintiff-appellant Janet Crane was Tucker’s grandmother and the administrator of his estate. She sued on his estate’s behalf: (1) making Eighth Amendment claims against four prison officials (the “CUCF Defendants”); (2) making statutory claims for violations of the Americans with Disabilities Act (“ADA”) and the Rehabilitation Act against UDC; and (3) making a claim under the Unnecessary Rigor Clause of the Utah Constitution against both the CUCF Defendants and UDC. The defendants moved for judgment on the pleadings. The district court granted the motion, holding the CUCF Defendants were entitled to qualified immunity on the federal constitutional claims and the federal statutory claims did not survive Tucker’s death. As a result, the district court declined to exercise supplemental jurisdiction over the state constitutional claim. Finding no reversible error in the district court's dismissal, the Tenth Circuit affirmed. View "Crane v. Utah Department of Corrections, et al." on Justia Law

In 2015, Yost was charged with multiple counts of first-degree murder in connection with the fatal stabbing of his former girlfriend, Randall. After Yost was convicted, he notified the court that he had just learned that his appointed counsel, Rau, had represented Randall in a past case; he requested a new trial. Rau also filed a motion for a new trial but did not reference Yost’s allegations of a conflict of interest. The court denied the motion and sentenced Yost to 75 years’ imprisonment. After conducting a preliminary inquiry on remand, the trial court concluded that the allegations had merit and appointed new counsel, Lookofsky, to investigate. Yost’s amended motion for a new trial alleged that Rau had represented Randall, on two prior occasions in an unrelated case. Yost waived any conflict of interest based on Lookofsky’s prior hiring of Rau on an unrelated civil matter and any conflict-of-interest claims based on the judge’s prior representation of Yost’s family members.The court concluded that there was no per se conflict of interest, which would have required automatic reversal of the conviction, absent a waiver. The Illinois Supreme Court agreed. Illinois now recognizes three per se conflicts of interest: when defense counsel has a contemporaneous association with the victim, the prosecution, or an entity assisting the prosecution; when defense counsel contemporaneously represents a prosecution witness; and when defense counsel was a former prosecutor who was personally involved in the defendant's prosecution. Yost did not claim an actual conflict of interest. View "People v. Yost" on Justia Law

The 2012 Cook County Firearm Tax Ordinance imposed a $25 tax on the retail purchase of a firearm within Cook County. A 2015 amendment to the County Code included a tax on the retail purchase of firearm ammunition at the rate of $0.05 per cartridge for centerfire ammunition and $0.01 per cartridge for rimfire ammunition. The taxes levied on the retail purchaser are imposed in addition to all other taxes imposed by the County, Illinois, or any municipal corporation or political subdivision. The revenue generated from the tax on ammunition is directed to the Public Safety Fund; the revenue generated from the tax on firearms is not directed to any specified fund or program.Plaintiffs alleged that the taxes facially violate the Second Amendment to the U.S. Constitution and the Illinois Constitution concerning the right to bear arms and the uniformity clause, and are preempted by the Firearm Owners Identification Card Act and the Firearm Concealed Carry Act. The trial court rejected the suit on summary judgment. The appellate court affirmed.The Illinois Supreme Court reversed. To satisfy scrutiny under a uniformity challenge, where a tax classification directly bears on a fundamental right, the government must establish that the tax classification is substantially related to the object of the legislation. Under that level of scrutiny, the firearm and ammunition tax ordinances violate the uniformity clause. View "Guns Save Life, Inc. v. Ali" on Justia Law

The Kankakee County State’s Attorney authorized the secret recording of a controlled drug purchase between a confidential informant and another individual. Davis was not the person to be recorded. When the informant went to the target’s home, he could not locate him. The informant walked to the porch of a different home and conducted a drug transaction with Davis, which was recorded by a hidden device. At the hearing on Davis’s motion to suppress, the parties agreed that the audio portion of the recording violated the eavesdropping statute. The circuit court granted the motion, finding that there was an illegal overhear conversation between Davis and the informant that took place before the drugs were seen in the video so that the video recording was the fruit of the poisonous tree that must be suppressed and the informant could not testify concerning the drug transaction.The Appellate Court reversed. The Illinois Supreme Court affirmed. The informant was a participant in the conversation, so his knowledge of that conversation was not derived from the illegal audio recording; the video recording was made simultaneously with the audio recording and could not have been derived from the audio recording. Because neither the informant’s testimony nor the video recording was obtained as a result of the illegal audio recording, the fruit of the poisonous tree doctrine does not apply. The evidence was admissible. View "People v. Davis" on Justia Law

The Illinois State Police obtained warrants to search a personal computer owned by Peoria Police Officer McCavitt, for digital evidence of two unrelated incidents: an aggravated criminal sexual assault and the unauthorized video recording and live video transmission of an unnamed victim. McCavitt was tried and acquitted of the alleged sexual assault before the unauthorized video recording was investigated. Following his acquittal, without seeking a new warrant, the Peoria Police Department searched a copy of the computer’s hard drive, uncovering evidence of the unauthorized video recording. The digital search also uncovered child pornography, which was not mentioned in the warrant. Based on the images, McCavitt was convicted of several counts of child pornography.The Illinois Supreme Court upheld the denial of McCavitt’s motion to suppress. Under the unique facts of this case, the search that uncovered child pornography did not violate McCavitt’s Fourth Amendment rights. The warrant at issue diminished McCavitt’s reasonable expectation of privacy in the images and videos he stored on his computer. When he was acquitted of the sexual assault, his reasonable expectation of privacy in his data relating to that offense was restored. However, the acquittal did not resolve the portion of the warrant that authorized a search for digital evidence of the unauthorized video recording. The post-acquittal computer examination was reasonably directed at obtaining that evidence and the child pornography found during the search was admissible because it was found in plain view. View "People v. McCavitt" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of three drug trafficking offenses after law enforcement officers discovered cocaine and heroin inside of his vehicle, holding that the district court did not err in denying Defendant's motion to suppress.In his motion to suppress, Defendant argued that the officers stopped his vehicle without reasonable suspicion, in violation of the Fourth Amendment, and therefore, the drugs found inside of the vehicle were inadmissible as evidence. The district court denied Defendant's motion to suppress. The First Circuit affirmed, holding that the officers had probable cause to arrest Defendant when they conducted the vehicle containment in this case. View "United States v. Gonzalez" on Justia Law

In 2009, Augustin asked Jordan to “find somebody” who sold cocaine. “Hoss,” subsequently sold Augustin six ounces of cocaine for $5,100. The deal went bad and Augustin kidnapped Jordan at gunpoint. Augustin’s associate released Jordan. Augustin was arrested. From prison, Augustin tried to arrange for a hitman to kill Jordan. The district court ultimately sentenced Augustin to a 380-month term for seven counts of conviction plus a consecutive 120-month term under 18 U.S.C. 924(c) for using a firearm during a crime of violence. After an unsuccessful appeal, Augustin unsuccessfully moved to vacate, set aside, or correct his sentence under 28 U.S.C. 2255.Later, Augustin filed a second or successive section 2255 motion, arguing that his section 924(c) conviction was unlawful under the Supreme Court’s 2019 “Davis” decision. The district court agreed. Rather than resentencing Augustin, the court corrected his sentence by vacating the section 924(c) conviction and its consecutive 120-month sentence. The Sixth Circuit affirmed. Augustin’s section 924(c) sentence played no role in the district court’s calculation of his other sentences. View "United States v. Augustin" on Justia Law