Justia Civil Rights Opinion Summaries

A California court sentenced appellant Plaintiff to death. That same year, the California legislature codified a longstanding judicial rule guaranteeing the appointment of postconviction relief counsel to indigent prisoners who had been convicted and sentenced to death. Plaintiff requested the appointment of postconviction habeas counsel 26 years ago. Plaintiff filed this action under 42 U.S.C. Section 1983, claiming that by failing to appoint counsel as promised and so preventing him from developing and prosecuting his state habeas corpus petition for over two decades, state officials are violating his procedural due process rights. He sought a declaration that state officials’ “failure to timely appoint counsel is in violation” of his due process rights. The district court dismissed his complaint for failure to state a claim.The Ninth Circuit reversed the district court’s dismissal. The panel held that Plaintiff has standing because he has adequately shown that the declaratory relief he seeks would redress his injuries. The panel agreed with the district court that abstention under O’Shea v. Littleton, as to Plaintiff’s individual request for declaratory relief, was not appropriate. The panel held that California is under no federal constitutional obligation to appoint postconviction counsel for all indigent capital prisoners. But Plaintiff stated a viable due process claim by alleging that he has been deprived of a valuable property interest for over a quarter century. The panel reversed the district court’s dismissal of Plaintiff’s complaint. However, the panel held that Plaintiff’s complaint, as presently drafted, did not plausibly allege that the state has failed to adequately protect his liberty interest in petitioning for habeas corpus. View "STEPHEN REDD V. PATRICIA GUERRERO, ET AL" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's denial of Defendant's motion to suppress and finding no error in her criminal trial, holding that the search for evidence in this case violated the Fourth Amendment and that remand was required.Defendant was convicted of trafficking in methamphetamine, possession with intent o manufacture, sell, or deliver methamphetamine, and possession of methamphetamine. The court of appeals affirmed. The Supreme Court reversed, holding (1) the search and subsequent seizure of contraband did not comport with the Fourth Amendment; and (2) remand was required for the trial court to determine if the evidence should be suppressed pursuant to the exclusionary rule. View "State v. Julius" on Justia Law

The Supreme Court affirmed the judgment of the district court overruling Defendant's motion to suppress and convicting her of possession of methamphetamine and drug paraphernalia following a stipulated bench trial, holding that the district court did not err when it overruled Defendant's motion to suppress.In denying Defendant's suppression motion, the trial court concluded that Defendant consented to a search of her vehicle, in which certain illegal items were found, and that a subsequent search of Defendant's person occurred incident to a valid arrest. The Supreme Court affirmed, holding (1) probable cause existed to arrest Defendant, and the subsequent search of her person occurred incident to a valid arrest; and (2) Defendant was not entitled to relief on her remaining allegations of error. View "State v. Hammond" on Justia Law

Fieste was charged with threatening to assault and murder two federal judges, three former U.S. presidents, and the current President. She is currently incompetent to stand trial. Fieste's mental illness causes her to experience delusions. In custody, Fieste refused the antipsychotic medication that experts believe will restore her competence. The government obtained permission to involuntarily medicate her to render her competent to stand trial. The order was stayed pending appeal.The Seventh Circuit affirmed but remanded. Fieste’s pretrial detention is insufficient to overcome the government’s interest in prosecution although Fieste’s anticipated Guidelines range is 12-18 months and she will “likely face a sentence of time served” if convicted. The district court properly conducted a holistic assessment to conclude that the proposed treatment plan is substantially likely to render Fieste competent and that the side effects are substantially unlikely to significantly interfere with her ability to participate in the proceedings. The order permitted Fieste to be medicated with “long-acting injectable anti-psychotic medication, along with other medications” suggesting impermissible flexibility to administer unspecified medications. The district court must provide a dosage range based on the expert’s recommendation or some other appropriate evidence, whether directly in its order or by incorporating a sufficiently detailed treatment plan. View "United States v. Fieste" on Justia Law

The First Circuit reversed the decision of the district court granting summary judgment for Appellants on their claim brought under Title IX of the Education Amendments of 1972, holding that the district court should not have dismissed the Title IX claim.MG, a minor child, alleged that he was harassed by fellow students while he was attending Brooke Charter School East Boston. Appellants - MG's mother, on behalf of herself, MG, and his four minor siblings - brought suit against the school asserting claims under Title IX, the Equal Protection Clause of the Fourteenth Amendment, and Massachusetts state law. The federal district court granted summary judgment for the school on all claims. The First Circuit reversed the summary judgment on Appellants' Title IX claim and remanded the case, holding that genuine issues of material fact precluded summary judgment on the Title IX claim. View "Grace v. Board of Trustees" on Justia Law

Plaintiff’s son spent several months at a medium-security facility in St. Louis called “the Workhouse.” None of the guards saw Plaintiff’s son receive or take fentanyl, the drug that killed him. Inmates tried to help by rubbing ice on him once he lost consciousness. Upon arriving a few minutes later, three Officers radioed for medical assistance. In the meantime, rather than try to resuscitate Plaintiff’s son themselves, they stood by and watched as two inmates tried to help him. When trained medical personnel finally arrived four minutes later, it was too late: they were unable to revive Plaintiff’s son, who died from an overdose. Surveillance footage captured some, but not all, of these events. Plaintiff’s mother sued the City of St. Louis, the three responding officers, and two supervisors for their deliberate indifference. The district court denied summary judgment to the responding officers.   The Eighth Circuit vacated and remanded. The court held that the district court misstated the burden and relied on allegations from an unverified complaint to deny summary judgment. The court wrote that the district court erred in how it dealt with the gaps in the video footage. Instead of relying on other evidence to fill in the missing details, the findings mirrored what the plaintiff’s unverified complaint said. The court wrote that unsworn allegations are no substitute for evidence at summary judgment. The court explained that the district court tilted the scales too far in the Plaintiff’s favor by raising the summary-judgment burden on the officers and allowing unsworn allegations to rebut evidence. View "Janice Washington v. City of St. Louis, Missouri" on Justia Law

Lighthart had dated both Buchanan and the victim, who was known to have access to large amounts of money. Lighthart drove the victim to a residence, knowing that Buchanan was there intending to rob the victim. Buchanan beat the victim, demanding money, and eventually shot him to death. Lighthart then injected the victim with a solution that contained Drano or attempted to do so. After cleaning the scene, they disposed of the body by setting it on fire inside the victim’s Jeep in a rural field. In 2004, Lighthart, then 23, entered a partially negotiated plea of guilty to first-degree murder, in exchange for the dismissal of other charges and a sentencing cap of 35 years. Lighthart filed a motion to reduce her 35-year sentence and, subsequently, an untimely pro se motion to withdraw her plea, asserting that she was the victim of domestic violence and ineffective assistance of counsel. After an 11-½ year delay following remand and changes in counsel, the appellate court affirmed the dismissal of her 725 ILCS 5/122-1 post-conviction petition as untimely.The Illinois Supreme Court reversed. An ineffective notice of appeal from a negotiated guilty plea, which is dismissed for lack of appellate jurisdiction due to failure to follow procedural requirements (Illinois Supreme Court Rule 604(d)) triggers a six-month limitations period for bringing a postconviction petition. However, under the circumstances, Lighthart could not have been culpably negligent in the untimely filing of her petition. View "People v. Lighthart" on Justia Law

In 2012, Givens, Dudley, and Strong burglarized a store and attempted to escape by backing a van out of a closed garage door, striking a police officer. Chicago police officers fired their weapons at the van, resulting in Strong’s death and injuries to Dudley and Givens, who were convicted of felony murder, aggravated battery to a peace officer, and possession of a stolen motor vehicle.Dudley, Givens, and Strong’s estate sued the City, alleging the use of excessive force. With respect to Dudley and Givens, the circuit court granted Chicago summary judgment based on the collateral estoppel effect of their prior criminal proceedings. The estate’s lawsuit resulted in a partial verdict for the estate. The circuit court granted Chicago’s motion for judgment notwithstanding the verdict (JNOV) based on the jury’s answers to special interrogatories. The appellate court reversed, holding that collateral estoppel did not bar Dudley and Givens from litigating their claims and the circuit court erred in vacating the verdict.The Illinois Supreme Court agreed that collateral estoppel did not bar the suit by Dudley and Givens. Chicago did not establish with “clarity and certainty” that the identical question was decided in the earlier proceeding The court reinstated the JNOV. The circuit court properly held that the jury’s special finding related to an ultimate issue of fact upon which the rights of the parties depended and was clearly and absolutely irreconcilable with the verdict returned. View "Givens v. City of Chicago" on Justia Law

Pacheco was convicted of aggravated assault and other offenses after he tried to hit a Joliet police officer with his car. During the incident, the officer shot and injured Pacheco. The appellate court reversed, finding that the trial court violated Pacheco’s right to confrontation by prohibiting defense counsel from cross-examining the officer who shot Pacheco as to whether the officer believed he could lose his job if the shooting was found to be unjustified and finding the trial court erred in granting the prosecution’s motion in limine to bar defense counsel from asking the officer and his partner why they did not write police reports regarding the incident.The Illinois Supreme Court reversed the appellate court and remanded. The limitation imposed on the officer’s cross-examination was necessary to avoid a highly prejudicial outcome to Pacheco–the admission of testimony that a review panel had found the shooting to be justified. Cross-examination was not otherwise limited. Because of department policy, the officers had no choice about writing reports and their failure to do so was irrelevant to any question of bias or credibility. The question would have distracted the jury from the question of determining the guilt or innocence of Pacheco. View "People v. Pacheco" on Justia Law

The DEA placed a tracking device on Tousis’s car. On June 2, agents believed that Tousis would go to Turner’s Aurora home to procure drugs. They watched Tousis enter Turner’s garage carrying a bag, and then leave carrying the bag, which had changed in appearance, suggesting a drug transaction. The Sheriff’s Department attempted a traffic stop. Tousis fled; the tracking device showed 115.2 miles per hour on I-88. Agent Billiot, driving an unmarked car, followed Tousis off the highway. Tousis was then driving at normal speeds, but taking evasive actions. At a red light, Billiot activated his emergency lights and siren, and pulled in front of Tousis’s car, 10-25 feet away. Billiot grabbed his firearm, exited his car wearing a DEA vest, and ran toward Tousis’s car, shouting commands.As Tousis moved the car forward, with nothing between Billiot and Tousis’s car, Billiot fired a single shot. The bullet struck the steering wheel; a fragment hit Tousis in the neck as he was maneuvering his vehicle away from Billiot. Tousis’s car then accelerated and struck a light pole. Tousis died. Officers recovered 300 grams of cocaine from Tousis’s car.In a suit under 42 U.S.C. 1983, the district court denied Billiot qualified immunity. The Seventh Circuit reversed. The material undisputed facts demonstrate that Billiot fired the fatal shot fearing for his own safety and for that of the public if Tousis resumed his reckless flight. There was no precedent warning Billiot that his actions amounted to excessive force. View "Tousis v. Billiot" on Justia Law