Justia Civil Rights Opinion Summaries

Three practicing Muslim men alleged that federal agents asked them to serve as informants in Muslim communities. When they refused, the agents placed or retained them on the "No Fly List" and suggested they could be removed from the list if they agreed to work as informants. The plaintiffs sought damages under the Religious Freedom Restoration Act (RFRA), claiming that their religious beliefs precluded them from serving as informants and that the agents substantially burdened their exercise of religion by conditioning their removal from the No Fly List on actions that violated those beliefs.The United States District Court for the Southern District of New York dismissed the complaint on qualified immunity grounds, concluding that the agents were entitled to qualified immunity because there was no clearly established right not to be pressured to inform on members of one's religious community through the coercive or retaliatory use of the No Fly List.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The court held that the agents were entitled to qualified immunity because a reasonable person in their position would not have understood that their conduct implicated the plaintiffs' religious beliefs. The court noted that the plaintiffs did not disclose their religious objections to the agents, and there were no facts plausibly supporting the conclusion that the agents knew the plaintiffs' objections were grounded in their religious beliefs. Therefore, the agents were entitled to qualified immunity from damages in their personal capacities. View "Tanvir v. Tanzin" on Justia Law

A man was unable to purchase a firearm because a background check revealed he was subject to a long-term domestic violence protective order (DVPO). He sued the State, claiming he was no longer subject to a protective order as defined by federal statute and sought a permanent injunction and declaratory judgment to have the Department of Public Safety (DPS) notify a national database that he was no longer subject to a protective order under 18 U.S.C. § 922(g)(8). He filed a motion for summary judgment, which the State opposed, filing a cross-motion for summary judgment. The superior court granted the State’s cross-motion, and the man appealed.The superior court found that the DVPO had not expired and remained a qualifying order under Section 922(g)(8). It also concluded that the man’s constitutional claims were not ripe because he had not initiated modification or dissolution of the order. The court entered a final judgment in favor of the State.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court’s decision. The court held that the DVPO remained in effect and was a qualifying order under 18 U.S.C. § 922(g)(8). The court found that the legislative history supported the interpretation that DVPOs issued under AS 18.66.100(c)(1) are effective until further order of the court. The court also concluded that the man’s remaining claims were not ripe for adjudication because he had not attempted to dissolve or modify the DVPO. View "Eng v. State" on Justia Law

The case involves a petition challenging the public release of a grand jury report by the 30th County Investigating Grand Jury. The petitioner argued that the report did not meet the statutory definition of an "investigatory grand jury report" under the Investigatory Grand Jury Act (IGJA) and that the supervising judge erred in ordering its release. The petitioner also contended that the report's criticism of named, unindicted individuals violated their due process rights and the fundamental right to reputation under the Pennsylvania Constitution.The Philadelphia County Court of Common Pleas initially accepted the report and ordered its public release. The supervising judge provided notice and an opportunity to respond to some, but not all, named, unindicted individuals criticized in the report. The petitioner, along with others, sought to have the report permanently sealed or redacted. The supervising judge made some redactions but ultimately ordered the report to be unsealed.The Supreme Court of Pennsylvania reviewed the case and concluded that the report did not satisfy the IGJA's definition of an "investigatory grand jury report" because it neither related to organized crime or public corruption nor proposed recommendations for legislative, executive, or administrative action in the public interest. The court found that the report focused on punishing specific individuals and providing answers to the deceased-accused's family, rather than addressing broader public concerns.The court also determined that due process requires notice and an opportunity to respond for all named, unindicted individuals criticized in a grand jury report. The supervising judge's failure to provide such notice to all criticized individuals was deemed an error. Consequently, the Supreme Court vacated the supervising judge's order and remanded the case with instructions to permanently seal the report. View "In Re: The Thirtieth County Investigating Grand Jury" on Justia Law

The case involves Warren Balogh, who participated in the "Unite the Right" rally in Charlottesville, Virginia. The rally, organized to protest the removal of a Robert E. Lee statue, quickly turned violent between protesters and counterprotesters. Balogh alleged that the Charlottesville Police, under Chief Al Thomas, and the Virginia State Police, under Lieutenant Becky Crannis-Curl, failed to protect his First and Fourteenth Amendment rights by not intervening in the violence and declaring an unlawful assembly, which he claimed amounted to a heckler's veto.The United States District Court for the Western District of Virginia dismissed Balogh's complaint under Federal Rule of Civil Procedure 12(b)(6). The court found that the defendants were entitled to qualified immunity because there was no clearly established right to police intervention to protect First Amendment rights from third-party violence. The court also held that Balogh failed to state a plausible claim for relief under the First and Fourteenth Amendments, noting that the police did not selectively enforce the unlawful assembly order and that Balogh's allegations of intentional discrimination were conclusory.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The Fourth Circuit held that the First Amendment does not obligate police to protect protesters' constitutional rights amid violence, explicitly stating that the First Amendment is a shield against invasive speech regulations, not a sword to wield against violent disruptions. The court also found that Balogh's equal protection claim under the Fourteenth Amendment failed because he did not provide sufficient facts to show intentional or purposeful discrimination. Additionally, the court rejected Balogh's Monell claim against the City of Charlottesville, as he did not demonstrate that the City Manager, the final policymaker, had ratified or delegated authority to Chief Thomas. View "Balogh v. Virginia" on Justia Law

The plaintiffs, parents of minor children, challenged a public act that eliminated the religious exemption from vaccination requirements for school enrollment. They argued that the act violated their constitutional rights to free exercise of religion, equal protection, and a free public education, as well as their statutory rights under Connecticut law. The defendants, state and municipal officials, moved to dismiss the case on the grounds of sovereign immunity.The trial court denied the defendants' motions to dismiss, concluding that the plaintiffs' constitutional claims satisfied the substantial claim exception to sovereign immunity, and their statutory claim under Connecticut law satisfied the statutory waiver exception. The defendants appealed this decision.The Connecticut Supreme Court reviewed the case and determined that the trial court must assess the legal sufficiency of the plaintiffs' allegations to determine whether they have asserted a substantial claim of a constitutional violation. The court concluded that the plaintiffs' constitutional claims failed as a matter of law. The act was deemed a neutral law of general applicability, rationally related to the state's interest in protecting public health. The court also found that the act did not violate the plaintiffs' right to a free public education, as it imposed a reasonable vaccination requirement.However, the court agreed with the trial court that the plaintiffs' statutory free exercise claim under Connecticut law satisfied the statutory waiver exception to sovereign immunity. The court found that the scope of the waiver extended to free exercise challenges to the enforcement of legislation and that applying the statute to the public act did not violate any constitutional principles.The Connecticut Supreme Court reversed the trial court's decision in part, directing the dismissal of the constitutional claims, but affirmed the decision regarding the statutory claim, allowing it to proceed. View "Spillane v. Lamont" on Justia Law

In 2006, an individual was convicted of first-degree sexual abuse and later subjected to civil management under New York's Mental Hygiene Law due to a "mental abnormality." Initially confined, he was released to a strict and intensive supervision and treatment (SIST) program in 2016. In 2019, he violated SIST conditions by tampering with an alcohol monitoring bracelet, leading to his temporary confinement based on a psychologist's evaluation and a probable cause finding by the court.The Supreme Court initially found probable cause to believe he was a "dangerous sex offender requiring confinement" and ordered his detention pending a final hearing. He filed a habeas corpus petition, arguing that the statutory scheme violated procedural due process by not providing an opportunity to be heard at the probable cause stage. The Supreme Court denied the petition, and the Appellate Division converted the proceeding to a declaratory judgment action, ultimately declaring the statute constitutional.The New York Court of Appeals reviewed the case and upheld the lower court's decision. The court held that the statutory scheme under Mental Hygiene Law § 10.11 (d) (4) appropriately balances individual and state interests. It concluded that the statute provides sufficient procedural safeguards, including a prompt judicial probable cause determination and a full hearing within 30 days, to mitigate the risk of erroneous confinement. The court found that the petitioner failed to demonstrate that the statute is unconstitutional either on its face or as applied to him. The order of the Appellate Division was affirmed without costs. View "People ex rel. Neville v Toulon" on Justia Law

A juvenile court judge in Hamilton County, Ohio, presided over the trial of a thirteen-year-old accused of felonious assault. The judge found the juvenile not delinquent and sealed the case record under Ohio Revised Code (R.C.) 2151.356(B)(1)(d). After the juvenile was later killed, the Cincinnati Enquirer requested the trial transcript, which the judge denied, citing the statute.The Cincinnati Enquirer challenged the constitutionality of R.C. 2151.356, arguing that the Ohio Constitution's open courts provision prohibits sealing court records without an individualized determination balancing the interests of the juvenile and the public. The juvenile court judge argued that the open courts provision does not apply to juvenile delinquency proceedings, relying on precedent from the Ohio Supreme Court.The Supreme Court of Ohio reviewed the case and held that the open courts provision of the Ohio Constitution applies to juvenile delinquency proceedings. The court determined that R.C. 2151.356 is unconstitutional because it mandates the sealing of records without an individualized balancing of interests. The court granted a writ of mandamus ordering the juvenile court judge to provide access to the trial transcript and a writ of prohibition preventing the enforcement of the sealing order. View "State ex rel. Cincinnati Enquirer v. Bloom" on Justia Law

In this case, the petitioner was convicted by a jury in New Hampshire state court for the first-degree murder of Larry Lemieux. The petitioner admitted to shooting Lemieux but claimed he acted in self-defense or in defense of another, arguing he did not act with premeditation. After his conviction, the prosecution disclosed a proffer letter recommending a suspended sentence for drug charges against Jose Gomez, a key prosecution witness. The petitioner argued that the failure to disclose this letter violated his due process rights under Brady v. Maryland.The state trial court denied the petitioner's motion for a new trial, finding that the nondisclosure of the proffer letter did not prejudice the petitioner. The New Hampshire Supreme Court affirmed this decision, holding that the petitioner was not prejudiced under New Hampshire law, which sets stricter standards than Brady. The court found that the undisclosed evidence would not have altered the defense strategy or the trial's outcome, given the overwhelming additional evidence of premeditation presented by other witnesses.The United States Court of Appeals for the First Circuit reviewed the case, focusing on whether the New Hampshire Supreme Court's decision involved an unreasonable application of clearly established federal law under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The First Circuit affirmed the denial of habeas relief, concluding that the New Hampshire Supreme Court reasonably determined that the petitioner was not prejudiced by the nondisclosure of the proffer letter. The court noted the overwhelming evidence of premeditation from multiple witnesses, which supported the jury's verdict independent of Gomez's testimony. View "Etienne v. Edmark" on Justia Law

In February 2020, a police officer in Wauwatosa, Wisconsin, shot and killed a Black teenager, Alvin Cole. Following the incident, community members organized protests against police violence and racism. Anticipating unrest after the district attorney decided not to charge the officer, the mayor imposed a curfew. Plaintiffs, affected by the curfew and police conduct, filed constitutional and state law claims against the City of Wauwatosa and individual defendants.The United States District Court for the Eastern District of Wisconsin dismissed most claims, allowing only First Amendment and Driver’s Privacy Protection Act (DPPA) claims to proceed. The court later granted summary judgment for the defendants on the First Amendment claims, leaving only the DPPA claims for trial. The jury ultimately ruled in favor of the defendants on the DPPA claims.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the curfew was a permissible time, place, and manner restriction under the First Amendment. The court found that the curfew was content-neutral, served a significant government interest in public safety, was narrowly tailored, and left open ample alternative channels for communication. The court also upheld the dismissal of the plaintiffs' § 1983 claims against individual defendants, agreeing that the claims were inadequately pleaded and that the district court did not abuse its discretion in denying further amendments. Lastly, the court found no abuse of discretion in the district court’s response to a jury question regarding the definition of “personal information” under the DPPA. The judgment of the district court was affirmed. View "Knowlton v. City of Wauwatosa" on Justia Law

David Dajuanta Wallace was convicted of felony murder and a firearm offense related to the shooting death of Darius Bottoms. Wallace argued that the evidence was insufficient, that his due process rights were violated by being required to wear a leg iron and prison clothing during the trial, and that he received ineffective assistance of counsel.A Fulton County grand jury indicted Wallace and two co-defendants for various crimes, including felony murder and gang activity. Wallace pled guilty to some charges and went to trial on others. The jury found him guilty of felony murder and a firearm offense. The trial court sentenced him to life in prison with the possibility of parole for felony murder and an additional five years for the firearm charge. Wallace's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and found that the evidence was sufficient to support Wallace's convictions. The court held that the testimony of an accomplice was corroborated by other evidence, satisfying Georgia statutory law. Constitutionally, the evidence allowed the jury to find Wallace guilty as a party to the crimes rather than merely an accessory after the fact. The court also determined that any error related to Wallace wearing a leg iron was harmless beyond a reasonable doubt, given that the jury could not see the leg iron, Wallace used it strategically, and the strong evidence of his guilt.Regarding ineffective assistance of counsel, the court concluded that Wallace failed to show either deficiency or prejudice. The court affirmed Wallace's convictions and the trial court's rulings. View "WALLACE v. THE STATE" on Justia Law