Justia Civil Rights Opinion Summaries

In 2018, Florida voters approved Amendment 4, a state constitutional amendment that automatically restored voting rights to ex-felons who had completed all of the terms of their sentences. Plaintiffs filed suit challenging the constitutionality of the "legal financial obligation" (LFO) requirement in Senate Bill 7066, which implemented the Amendment and required payment of all fines, fees, and restitution imposed as part of the sentence. The district court issued a preliminary injunction requiring the state to allow the named plaintiffs to register and vote if they are able to show that they are genuinely unable to pay their LFOs and would otherwise be eligible to vote under Amendment 4.In 2020, the Eleventh Circuit affirmed the preliminary injunction with respect to the “wealth discrimination” claims. In 2021, the Eleventh Circuit affirmed the rejection of an Equal Protection claim based on gender discrimination, on behalf of “low-income women of color who face unemployment, low wages, and difficulty paying off their financial debts at much higher rates than their male and white female counterparts.” The plaintiffs could prevail on their constitutional challenges only if they could “show that gender was a motivating factor in the adoption of the pay-to-vote system,” and they presented no evidence of intentional discrimination. View "McCoy v. Governor of Florida" on Justia Law

Cox, a transgender woman, was assaulted at three different Georgia prisons for male inmates: At each of these institutions, Cox received estrogen injections, causing her to present with female features. Cox’s identity as a transgender woman within these male prisons made her a target for sexual and other physical abuse she was forced to endure at the hands of other inmates. Cox sued six Georgia Department of Corrections (GDC) officials, invoking 42 U.S.C. 1983, and alleging that the GDC officials, in failing to protect her, violated the Eighth Amendment. She further alleged that three GDC officials exhibited deliberate indifference to the substantial risk of serious harm she faced as a transgender inmate by failing to comply with the Prison Rape Elimination Act (PREA), 34 U.S.C. 30301.The Eleventh Circuit affirmed the dismissal of Cox’s suit. Cox failed to state a failure-to-protect Eighth Amendment claim; with respect to each defendant, she either failed to establish the subjective component of deliberate indifference or failed to allege facts suggesting that the defendant acted in an objectively unreasonable manner. The court rejected the PREA claims for the same reasons. View "Cox v. Deputy Warden" on Justia Law

The Second Circuit affirmed the district court's denial of plaintiffs' motion for a preliminary injunction directing defendant officials of the DOCCS to rescind changes in the scheduling of certain regularly-held Quaker religious gatherings at Green Haven Correctional Facility. The court agreed with the district court that a preliminary injunction is not warranted because plaintiffs are unable to demonstrate a likelihood of success on the merits of their claims.After determining that it has jurisdiction to address the merits of the appeal, the court concluded that, at least insofar as they challenge substantive restrictions on their ability to conduct religious services and meetings in accordance with their beliefs, plaintiffs have established that any violation of their religious liberties would satisfy the irreparable injury standard. However, the court concluded that the claims of Green Haven Meeting, as well as those of the Incarcerated Plaintiffs suing in their own names, must be dismissed for failure to exhaust administrative remedies. In regard to the Non-Incarcerated Plaintiffs, the court concluded that the changes in the times of the Quarterly Meetings, and the eventual cancellation of those meetings, did not infringe their rights under the Free Exercise Clause of the First Amendment. The court found persuasive defendants' contention that plaintiffs failed to clearly establish that defendants' actions concerning Quarterly Meetings substantially burden plaintiffs' exercise of religion since defendants rescheduled the meetings for Friday evenings and did not terminate them. Furthermore, the record reinforces the district court's conclusion that defendants' rescheduling decision was supported by legitimate concerns. Finally, the court concluded that the balance of equities and the public interest do not tip in favor of granting a preliminary injunction. View "Green Haven Prison Preparative Meeting v. New York State Dept. of Corrections" on Justia Law

The Supreme Court affirmed the decision of the court of appeals holding that a law enforcement officer lawfully expanded the scope of the underlying traffic stop in this case, holding the court of appeals did not err.Defendant was convicted of first-degree driving while impaired and possessing an opened bottle or receptacle containing an alcoholic beverage. On appeal, Defendant argued that the district court erred by denying his motion to suppress evidence because the officer impermissibly expanded the scope of the underlying traffic stop by asking Defendant if he had consumed any beer from the open case in his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding that the circumstances known to the officer and the legitimate inferences to be drawn from them raised a reasonable articulable suspicion of other criminal activity sufficient to expand the scope of the traffic stop. View "State v. Taylor" on Justia Law

The Supreme Court affirmed the judgment of the district court summarily denying Appellant's claims for postconviction relief, holding that the district court did not abuse its discretion.After a jury trial, Defendant was convicted of first-degree premeditated murder as a principal and as an aider and abettor and sentenced to life in prison without the possibility of release. Defendant later moved for postconviction relief, alleging that the State committed Brady violations during his criminal trial and other grounds for relief. The district court denied Defendant's petition for postconviction relief without holding an evidentiary hearing. The Supreme Court affirmed, holding that Defendant was not entitled to relief on his claims for postconviction relief. View "Thoresen v. State" on Justia Law

In 1989, Middlebrooks of felony murder and aggravated kidnapping and sentenced to death. His conviction and death sentence were upheld on direct and collateral review. When Middlebrooks was sentenced to death, electrocution was Tennessee’s only method of execution. In 2000, Tennessee adopted lethal injection as the default method of execution. Under current law, electrocution is an option for execution only if an inmate sentenced to death before 1999 chooses execution by electrocution; lethal injection is declared unconstitutional; or the Commissioner of the Tennessee Department of Correction (TDOC) certifies that a necessary lethal-injection ingredient is unavailable. Middlebrooks will not choose execution by electrocution. In 2018, TDOC adopted a three-drug protocol of midazolam, vecuronium bromide, and potassium chloride as an alternative to pentobarbital.Middlebrooks and other death row challenged the constitutionality of the three-drug protocol. Tennessee then eliminated the pentobarbital protocol The state court dismissed their complaint. The Tennessee Supreme Court affirmed, concluding that the plaintiffs failed to meet their burden of proving that pentobarbital was available as an alternative means of execution, although other states used pentobarbital in executions.The district court dismissed Middlebrooks’ 42 U.S.C. suit, citing res judicata. The Sixth Circuit reversed in part. Middlebrooks' facial challenge plausibly alleged new facts that allow a reasonable inference that pentobarbital is available to Tennessee for use in executions. Middlebrooks’s as-applied claim does not rest on any newly developed individual condition that would render impermissible the application of res judicata principles. View "Middlebrooks v. Parker" on Justia Law

The Supreme Court affirmed Defendant's convictions and restitution order, holding that any error did not require reversal of the convictions.Defendant was convicted of first-degree felony murder and aggravated burglary. The district judge sentenced Defendant to a hard twenty-five life sentence plus forty-three months and ordered him to pay $7,470 in restitution. The Supreme Court affirmed, holding (1) the district judge did not abuse its discretion in admitting two sets of statements; (2) the judge did not commit reversible error by twice denying Defendant's requests for a mistrial; (3) the aggravated burglary instruction was not clearly erroneous; (4) the prosecutor committed harmless error during closing arguments; (5) the cumulative effect of any errors did not deny Defendant a fair trial; and (6) Defendant's original restitution judgment was constitutionally firm. View "State v. Owens" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the restitution ordered against Petitioner by the district court, holding that the restitution did not violate Petitioner's right to a jury under both the Sixth Amendment of the United States Constitution and section 5 of the Kansas Constitution Bill of Rights.Defendant pled guilty to one count of conspiracy to commit burglary for providing the car which her boyfriend used to burglarize two houses. The boyfriend paid Defendant $200 when he returned the car. The district court ordered that Defendant and her codefendants pay the full amount of the State's requested restitution, $33,249, jointly and severally. The court of appeals affirmed. The Supreme Court affirmed, holding (1) criminal restitution does not violate the Sixth Amendment to the United States Constitution; and (2) the current structure of criminal restitution violates section 5 of the Kansas Constitution Bill of Rights but is remedied by severance. View "State v. Arnett" on Justia Law

Plaintiff filed suit challenging the South Dakota State Penitentiary's pornography policy under the First and Fourteenth Amendments. Plaintiff named as defendants four South Dakota corrections officials in their official capacities. The district court granted in part and denied in part the parties' motions for summary judgment.In regard to plaintiff's as-applied challenges, the Eighth Circuit applied the Turner v. Safely, 482 U.S. 78 (1987), factors and concluded that the district court erred in granting summary judgment for plaintiff on his claim that the policy is unconstitutional as applied to two erotic novels because defendants were within their discretion to censor these books. However, the district court properly granted summary judgment for plaintiff on his claim that the policy is unconstitutional as applied to the art book and nine pictures of Renaissance artwork.In regard to plaintiff's facial challenges, the court dismissed as moot plaintiff's claim that the prohibition on nudity is overbroad, but plaintiff's claim that the prohibition on sexually explicit content is overbroad remains a live case or controversy based on the court's reversal of the district court's ruling on his as-applied challenges regarding the erotic novels. The court read the policy in light of the doctrine of constitutional avoidance and concluded that plaintiff failed to show that the policy's prohibition on sexually explicit content is "substantially overbroad." The court concluded that although plaintiff's resolution of plaintiff's as-applied challenges does not moot his claim that the policy's prohibition on sexually explicit content is overbroad, this claim fails on the merits. Finally, the court dismissed as moot plaintiff's request for coercive sanctions, denied his request for compensatory sanctions, and denied plaintiff's request for sanctions for defendants' alleged violations of the district court's orders. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Sisney v. Kaemingk" on Justia Law

Breiterman was subjected to three disciplinary actions imposed by her employer, the U.S. Capitol Police. She was suspended after commenting to fellow employees that women had to “sleep with someone” to get ahead. She was later placed on administrative leave and ultimately demoted for leaking a picture of an unattended Police firearm to the press. Although Breiterman admitted to this misconduct, she sued the Police, alleging sex discrimination, retaliation in violation of the Congressional Accountability Act, 2 U.S.C. 1301, and unlawful retaliation for speech protected by the First Amendment.The D.C. Circuit affirmed summary judgment in favor of the Police. The Police provided legitimate, nondiscriminatory reasons for suspending Breiterman, placing her on administrative leave during an investigation into the media leak, and demoting her from a supervisory position; nothing in the record would allow a reasonable jury to conclude that those reasons were a pretext for discrimination or retaliation. Supervisors are entrusted with greater authority than officers, held to a higher standard, and disciplined more severely than officers for similar violations, so Breiterman’s nonsupervisory comparators are too dissimilar to draw any inference of discriminatory treatment. Even assuming some procedural deviation occurred, the deviations were not so irregular as to indicate unlawful discrimination. View "Breiterman v. United States Capitol Police" on Justia Law