Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of two counts of interfering with an officer, in violation of Conn. Gen. Stat. 53a-167a(a), holding that there was no error in the proceedings below.At issue on appeal was whether the trial court erred in denying Defendant's pretrial motion to suppress on the grounds that he was seized in violation of the Fourth Amendment when a marked police cruiser blocked the egress of his vehicle, which was parked with its engine running and Defendant asleep in the driver's seat. The Supreme Court affirmed, holding that no violation of the Fourth Amendment occurred because the responding officer was checking on Defendant's well-being pursuant to the officer's community caretaking function and was not engaged in an investigatory stop involving criminal activity. View "State v. Pompei" on Justia Law

In 2001, Sands was 24 years old when he committed special circumstance murder (Penal Code 187, 190.2(a)(10)) and was sentenced to a prison term of life without the possibility of parole. The trial court denied his motion, seeking to develop a record of mitigating circumstances for an eventual youth offender parole hearing under “Franklin.”The court of appeal affirmed, rejecting his Equal Protection argument. The statute provides an opportunity for release (via youth offender parole hearings) to most persons convicted of crimes committed before the age of 26 in their 15th, 20th, or 25th year of incarceration, depending on the sentence imposed for their “[c]ontrolling offense,” sections 3051(a)(2)(B), (b)(1)-(4). The statute excludes offenders who were sentenced to life without the possibility of parole for crimes they committed at age 18-25. The Legislature had a rational basis to distinguish between offenders with the same sentence (life without parole) based on their age. For juvenile offenders, such a sentence may violate the Eighth Amendment but the same sentence does not violate the Eighth Amendment when imposed on an adult, even an adult under the age of 26. The Legislature could rationally decide to remedy unconstitutional sentences but go no further. View "People v. Sands" on Justia Law

Before 2013, the Michigan Department of Corrections provided kosher meals with meat and dairy to Jewish prisoners and allowed charitable Jewish organizations to bring in traditional religious foods for Jewish holidays. In 2013, MDOC implemented a universal vegan meal for all prisoners who qualify for a religious diet and stopped allowing Jewish organizations to send food. Prisoners claiming that their religious convictions require them to eat a meal with kosher meat and one with dairy on the Jewish Sabbath and four Jewish holidays brought a class action on behalf of all Jewish MDOC prisoners under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc-1(a), arguing that the policy substantially burdens their sincere religious beliefs.The Sixth Circuit affirmed a judgment in the prisoners’ favor. Because MDOC’s policy completely bars the asserted practice here—eating meat and dairy at mealtime—the prisoners’ failure to buy meat and dairy products at the commissary does not undermine the sincerity of their belief. Even if the prisoners spent every penny on beef sticks and dry milk, prison policy would still bar their religious exercise of eating those items as part of their meals. There was evidence suggesting that these prisoners do in fact sincerely believe that cheesecake is required on Shavuot. View "Ackerman v. Washington" on Justia Law

A Xenia Police dispatcher contacted officer Reed about a double-parked vehicle with the person in the backseat allegedly “shooting up.” Reed observed a vehicle straddling the line between a standard parking spot and a handicap-only space; it was not displaying a handicap placard or license plate and was illegally parked. Prigmore opened the rear passenger door of the vehicle. Reed saw what appeared to be a handgun in the pocket of the door; he activated his body camera, unholstered his firearm, and secured the gun. With Prigmore out of the vehicle, Reed observed another firearm (a BB gun) on the seat where Prigmore had been sitting.Days later, federal agents arrested Prigmore for drug trafficking. The agents did not interview or Mirandize Prigmore immediately because he appeared to be “under the influence.” When he arrived at booking, Prigmore appeared coherent and stated—unprompted—“that gun was mine.” A warranted search of Prigmore’s residence uncovered a box of ammunition. Charged with possessing a firearm and ammunition as a felon, 18 U.S.C. 922(g)(1), Prigmore had a “volatile relationship” with his attorneys, resulting in two competency hearings. The Sixth Circuit affirmed his conviction and 120-month sentence, rejecting arguments that the district court erred in finding him competent to stand trial, should have granted his motions to suppress, and that his sentence was substantively unreasonable. View "United States v. Prigmore" on Justia Law

The Supreme Court affirmed the judgment of the district court determining that ASM, a middle-aged woman, needed to be involuntarily hospitalized pursuant to Wyo. Stat. Ann. 25-10-110 because she was mentally ill, as defined under section 25-10-101(a), holding that the district court did not err.Specifically, the Supreme Court held (1) upon review of the entire evidence, including ASM's testimony, the district court did not err when it found ASM to be mentally ill; and (2) the district court did not deny ASM her constitutional right to free exercise of religion under the United States and Wyoming constitutions when it ordered her involuntarily hospitalization in what ASM characterized as a "Catholic ritual of mortification" because ASM failed to establish that she was engaged in such a practice when she injured herself. View "ASM v. State" on Justia Law

The Court of Appeals reversed the order of the appellate division affirming Defendant's conviction of grand larceny in the third degree, holding that Defendant neither forfeited his right to counsel nor validly waived his right to appeal.After several of Defendant's attorneys withdrew from representing Defendant, Defendant was forced to represent himself. The jury found Defendant guilty as charged. At sentencing, pursuant to an agreement, Defendant signed a written waiver of his right to appeal in exchange for a recommendation of time served. County Court sentenced Defendant to time served. On appeal, Defendant argued that the appeal waiver was invalid and that his Sixth Amendment right to counsel had been violated. The appellate division affirmed. The Court of Appeals reversed and ordered a new trial, holding (1) the lower courts erred in determining that Defendant's conduct with assigned counsel was so egregious as to constitute forfeiture of the right to counsel; and (2) Defendant's appeal waiver was invalid. View "People v. Shanks" on Justia Law

The Court of Appeals affirmed the judgments of the trial courts in these two cases convicting Defendants of violating Administrative Code of the City of New York 19-190, known as the "Right of Way Law," holding that the statute is not unconstitutional.The Right of Way Law makes it a misdemeanor for a driver, while failing to exercise due care, to make contact with a pedestrian or bicyclist who has the right of way and thereby cause physical injury. Both defendants in these cases were charged with violating the Right of Way Law, a misdemeanor. Defendants argued that the law's ordinary negligence mens rea violated due process because the standard was impermissibly vague and legally insufficient. Defendants also made two preemption arguments. Both defendants were convicted. The Court of Appeals affirmed, holding that the Right of Way Law does not violate due process and is not preempted by state law. View "People v. Torres" on Justia Law

Marc was arrested and taken to the Madison County Detention Center (MCDC). Marc’s wife, Dawn, told the police that her husband had lung cancer and needed immediate medical attention. Marc’s medical records also stated that he had a blood clot in his leg. Dawn alleges that medical staff removed his pain medication patch, placed him on “inappropriate” psychoactive medications, and failed to provide him with his prescriptions. The medical contractor, Correct Care, refused to honor Marc’s scheduled chemotherapy appointments. Marc was transferred to Kentucky State Reformatory (KSR). He arrived with an elevated heart rate, difficulty breathing, and swelling in his leg. Staff withheld his prescribed medication, breathing treatments, and chemotherapy. Marc died less than a month after his arrest. His family was informed two days later. The autopsy revealed fluid accumulated in his lungs. Medical staff would have discovered this fluid if they had administered his prescribed breathing treatments.Dawn’s 42 U.S.C. 1983 Eighth Amendment complaint alleged supervisory liability against Erwin, Acting Commissioner of the Kentucky Department of Corrections, claiming that Erwin “accepted” Marc’s transfer into KSR and “would have been made aware of [Marc’s] medical conditions” and had promulgated and maintained some of KSR’s allegedly unconstitutional policies. Dawn alleged that Erwin was “specifically aware that Correct Care” had a pattern of failing to provide inmates with adequate health care. The Sixth Circuit ordered the dismissal of the claims against Erwin. Dawn's complaint did not allege any “active unconstitutional behavior” by Erwin nor explain how his behavior proximately caused Marc’s injuries; Erwin is entitled to qualified immunity. View "Crawford v. Tilley" on Justia Law

The Supreme Court reversed Defendant's convictions of battery against a law enforcement officer and intentional criminal threat, holding that the cumulative effect of five errors in Defendant's trial affected the trial's outcome.After a jury trial, Defendant was convicted of possession of marijuana, battery against a law enforcement officer, and intentional criminal threat. The court of appeals reversed the marijuana conviction and ordered a new trial on the marijuana charge and identified four other trial errors related to Defendant's remaining convictions but determined that, individually and collectively, they were harmless. The Supreme Court reversed the court of appeals and reversed Defendant's two remaining convictions, holding that the cumulative effect of five errors made during trial affected the trial's outcome. The Court remanded the case for a new trial. View "State v. Taylor" on Justia Law

Western Michigan University, a public university, requires student-athletes to be vaccinated against COVID-19 but considers individual requests for medical and religious exemptions on a discretionary basis. Sixteen student-athletes applied for religious exemptions. The University ignored or denied their requests and barred them from participating in any team activities. The student-athletes sued, alleging that University officials violated their free exercise rights.The district court preliminarily enjoined the officials from enforcing the vaccine mandate against the plaintiffs. The Sixth Circuit declined to stay the injunction and proceedings in the district court pending appeal. The court called the issue “a close call” but concluded the free exercise challenge will likely succeed on appeal. The University’s vaccine mandate does not coerce a non-athlete to get vaccinated against her faith because she, as a non-athlete, cannot play intercollegiate sports either way. The mandate does penalize a student otherwise qualified for intercollegiate sports by withholding the benefit of playing on the team should she refuse to violate her sincerely held religious beliefs. The court applied strict scrutiny and reasoned that the University did not establish a compelling interest in denying an exception to the plaintiffs or that its conduct was narrowly tailored to achieve that interest. View "Dahl v. Board of Trustees of Western Michigan University" on Justia Law