Justia Civil Rights Opinion Summaries

The Supreme Court vacated the judgment of the district court denying Defendant's motion to withdraw his guilty plea, denying Defendant's subsequent motion to dismiss the charges against him, and entering a judgment of conviction based on Defendant's guilty plea, holding that the district court erred in denying Defendant's motion to withdraw his guilty plea.Defendant entered into a guilty plea agreement based on charges of robbery and ownership or possession of a firearm by a prohibited person and then suffered a mental breakdown. Defendant sought to withdraw his guilty plea when he regained competency, alleging a violation of his right to a speedy trial and that his trial counsel provided ineffective assistance. The district court denied Defendant's motions and convicted him. The Supreme Court vacated the judgment below, holding that withdrawal was just and fair, and therefore, the district court erred in denying Defendant's motion to withdraw his guilty plea. View "Sunseri v. State" on Justia Law

After being spotted in a stolen car, Sanders fled from the police. He led them on a car chase, then on a foot chase. An officer eventually caught up to Sanders, who continued to struggle. An officer then commanded a police dog to bite Sanders’s leg. Sanders was finally subdued and charged with resisting arrest. Sanders ultimately pled “no contest” and filed a civil rights action alleging the use of the police dog was excessive force.The Ninth Circuit affirmed the dismissal of his claims barred by Heck v. Humphrey, under which a 42 U.S.C. 1983 claim must be dismissed if a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence unless the conviction or sentence has already been invalidated. While a defendant cannot be convicted of resisting arrest if an officer used excessive force at the time of the acts resulting in the conviction, Sanders could not stipulate to the lawfulness of the dog bite as part of his plea and then use the same act to allege an excessive force claim under section 1983. View "Sanders v. City of Pittsburg" on Justia Law

In 1995, Demetrulias was sentenced to death for the fatal stabbing of Miller. Demetrulias claimed that he killed Miller in a struggle initiated by Miller when Demetrulias visited his home to collect a $40 debt. The prosecution maintained that Demetrulias stabbed Miller in the commission of a robbery.The Ninth Circuit affirmed the denial of habeas corpus relief. Even if Demetrulias’s argument that the trial court violated his due process rights by allowing the prosecution to introduce victim character evidence in a preemptive attack on Demetrulias’s assertion of self-defense. is not barred by procedural default, the admission of the statements did not amount to constitutional error. The challenged testimony was brief and non-inflammatory and did not seek to portray Demetrius as evil but portrayed the victims as non-violent, Demetrulias also argued that if the court had given a claim-of-right instruction, the jury would have had a legal basis for finding that Demtrulias intended to collect a debt, not to rob Miller, thereby negating the specific intent to prove robbery, and would have acquitted Demetrulias of the sole special circumstance charge. Any error in failing to give the instruction was harmless as was any error in failing to give a requested instruction of voluntary manslaughter based on heat-of-passion. The California Supreme Court could reasonably have concluded that trial counsel made a reasonable strategic decision in not presenting evidence of organic brain damage and mental health diagnoses. View "Demetrulias v. Davis" on Justia Law

Golf Village owns, maintains, and administers a 900-acre planned community in Powell, including one of 11 separate lots in a commercial development. A 2003 “Declaration of Private Roads” refers to the use of private roads by each commercial lot owner, its employees, customers, and invitees. In 2010, one lot was transferred to the city for a municipal park. In 2018, the City began using three streets without Golf Village’s permission, removed a curb, and built a construction entrance. Golf Village sued (42 U.S.C. 1983), claiming that Powell has taken its property without just compensation or due process.The Sixth Circuit affirmed the dismissal of the suit. Golf Village did not establish the loss of its right to exclude; it could terminate the alleged taking by building a gate at the private street's entrance to ensure that everyone who drives on those streets is an invited guest. Under Golf Village’s analysis, any time the government took an action that made a property owner’s property more popular, regardless of what actions the property owner could take, there would be a taking. Any increased traffic, which may lead to additional maintenance costs, is merely a government action outside the owner’s property that causes consequential damages within. There are no material allegations that Golf Village cannot use and enjoy the private roads to the extent that it did before the City’s actions. View "Golf Village North, LLC v. City of Powell" on Justia Law

The Supreme Court affirmed the judgment of the appellate court dismissing Petitioner's appeal from the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner could not prevail on his claim of ineffective assistance of trial counsel.Petitioner was convicted of robbery in the first degree. Later, Petitioner filed a petition for a writ of habeas corpus, asserting that he had received ineffective assistance of counsel during plea negotiations prior to his trial. The appellate court dismissed the petition. The Supreme Court affirmed, holding that Petitioner failed to meet his burden of proving that his attorney did not adequately advise him of his maximum sentencing exposure if convicted of the lesser included offense of robbery in the third degree. View "Moore v. Commissioner of Correction" on Justia Law

Citing a budget deficit, Chicago’s Board of Education laid off 1,077 teachers and 393 paraprofessional educators in 2011. The Chicago Teachers Union and a class of teachers (CTU) sued, alleging that the layoffs discriminated against African-American teachers and paraprofessionals in violation of Title VII of the Civil Rights Acts of 1964 and the Civil Rights Act of 1991, 42 U.S.C. 2000e.The Seventh Circuit affirmed summary judgment in favor of the Board. While CTU made a prima facie case of disparate impact with evidence that African-Americans comprised approximately 30% of Union members at the time of the layoffs but made up just over 40% of Union members receiving layoff notices, the Board’s decision to tie layoffs to declining enrollment in schools was legitimate, job-related, and consistent with business necessity. Beyond noting the existence of open positions for which laid-off employees were qualified, CTU did not meet its burden of establishing that its proposed alternative of transferring employees was “available, equally valid and less discriminatory.” The Illinois statute’s designation of hiring discretion to principals neither promotes discrimination nor bears any relationship to the Board’s decision to tie layoffs to declining enrollment and the transfer alternative proposed by CTU is not consistent with the Collective Bargaining Agreement. CTU did not put forth any evidence of intentional discrimination by the Board. View "Chicago Teachers Union v. Board of Education of the City of Chicago" on Justia Law

Smith, a Muslim serving a life sentence, sued the Georgia Department of Corrections (GDOC) under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc, claiming that GDOC’s grooming policy, which prohibits inmates from growing facial hair over a half-inch in length, placed a substantial burden on his religious exercise. The district court rejected Smith’s RLUIPA claim, finding that “GDOC ha[d] offered logical and persuasive reasons to show that allowing untrimmed beards would be unmanageable for GDOC” and that “it is plausible that allowing a close security inmate like Smith an untrimmed beard could be dangerous for prison security.” Rather than rule in favor of GDOC, the district court fashioned a remedy that neither party had requested: it held that RLUIPA entitled Smith to grow a three-inch beard.The Eleventh Circuit vacated. The district court’s determination that it was reasonable for GDOC to conclude that allowing Smith to grow an untrimmed beard would be both unmanageable and dangerous was not clearly erroneous but its ruling requiring GDOC to allow Smith to grow a three-inch beard was improper and contrary to the Supreme Court’s 2015 holding, Holt v. Hobbs, that courts should consider only the plaintiff’s proposed alternatives in deciding whether there is an available less restrictive means for the government to further its compelling interests under RLUIPA. View "Smith v. Dozier" on Justia Law

Devereux suffered a major stroke during or around the period of his custody by Knox County for misdemeanor first-time DUI. Corrections officers were in and out of the holding cell where he sat motionless for several hours but did not provide medical attention until it was too late to mitigate the stroke’s effects. Devereux brought federal civil rights claims and negligence claims under the Tennessee Governmental Tort Liability Act (TGTLA), which waives sovereign immunity for certain claims, but not those arising from “civil rights.”The district court dismissed all of Devereux’s claims against the officers and his civil rights claims against Knox County. It declined to exercise supplemental jurisdiction over the TGTLA claims and dismissed them without prejudice, allowing Devereux to refile in state court. Knox County argued that the court should have retained jurisdiction and determined that the TGTLA’s “civil rights exception” necessarily barred Devereux’s negligence claims. The Sixth Circuit vacated in part. The best approach is to give Tennessee courts a fresh opportunity to consider whether the TGTLA claims ivolve civil rights. The court vacated “to prevent any issue of collateral estoppel in state court based on this aspect of the district court’s reasoning. The court declined to certify the issue to the Tennesse Supreme Court. View "Devereux v. Knox County" on Justia Law

Brawner was detained at the Scott County jail. On her written questionnaire, Brawner answered that she needed to continue her prescription medications, listing three controlled substances: suboxone, clonazepam, and gabapentin. She denied having a serious medical condition that required attention and denied having epileptic seizures. The officer noted that Brawner did not appear capable of understanding all the questions. There is conflicting evidence about whether Brawner’s intake form ever made it to the jail nurse. Days later, Brawner suffered multiple seizures and was taken to a hospital. A treating physician diagnosed her with epilepsy and prescribed Phenobarbital. The hospital was not told that Brawner had not been permitted to take her prescribed medications. At the jail doctor’s instruction, jail nurse Massengale discontinued Brawner’s Phenobarbital and instead administered Dilantin. Over the next several days, Brawner suffered multiple seizures before finally being taken to a hospital.Brawner sued, claiming she suffered permanent, debilitating injuries. The Sixth Circuit reinstated two of her claims. A reasonable jury could find that Brawner had an objectively serious medical need, and that Massengale was either subjectively aware of the risk to Brawner from suddenly discontinuing her medications, in keeping with County policy against distributing controlled substances at the jail and failed to respond reasonably to that risk, or that Massengale recklessly failed to act reasonably to mitigate that risk, by following a policy that allowed the jail to wait 14 days before conducting a medical examination. View "Brawner v. Scott County" on Justia Law

Marshall, while under the age of 21, wished to purchase a handgun from a federally licensed firearms dealer and sued to challenge the constitutionality of the federal laws and regulations that prohibited her from doing so while she was 18–20 years old. A divided panel of the Fourth Circuit found those laws violated the text, structure, history, and tradition of the Second Amendment. After the opinion was issued but before the mandate, Marshall turned 21, rendering her claims moot. She attempted to add parties and reframe her claimed injuries.The Fourth Circuit concluded that it is too late to revive the case and that it must be dismissed as moot. The court vacated the opinions and remanded with direction to dismiss. View "Hirschfeld v. Bureau of Alcohol, Firearms, Tobacco & Firearms" on Justia Law