Justia Civil Rights Opinion Summaries

In the fall of 2021, the League of United Latin American Citizens of Iowa (LULAC) filed a petition against the Iowa Secretary of State, the Iowa Voter Registration Commission, and several county auditors. LULAC challenged a 2008 permanent injunction from a different case, which prohibited the dissemination of voter registration forms in languages other than English under the Iowa English Language Reaffirmation Act. LULAC argued that the injunction was wrongly decided and sought its dissolution, along with a declaration that the Act allowed for non-English voting materials.The Iowa District Court for Polk County granted LULAC’s requests, dissolving the King injunction and issuing a declaratory judgment that the Act did not apply to voting materials. The court held that voting materials were necessary to secure the right to vote and thus fell within the rights exception of the Act.The Iowa Supreme Court reviewed the case and focused on the issue of standing. The court concluded that LULAC lacked standing to challenge the King injunction and the Secretary of State’s interpretation of the law. The court reasoned that LULAC’s general interest in the proper interpretation and enforcement of the law, as well as its resource diversion in response to the injunction, did not constitute a legally cognizable injury. The court emphasized that standing requires a specific personal or legal injury, which LULAC failed to demonstrate. Consequently, the Iowa Supreme Court reversed the district court’s decision and remanded the case for dismissal. View "League of United Latin American Citizens of Iowa v. Iowa Secretary of State" on Justia Law

Mr. Jorge Martinez was fatally shot by Officer Cheyenne Lee while being served with an emergency protective order. The incident began when Officer Lee arrived at Mr. Martinez's home, and a family member informed him that Mr. Martinez was asleep. Upon being awakened, Mr. Martinez told Officer Lee to leave. Officer Lee attempted to arrest Mr. Martinez, managing to handcuff one hand before a struggle ensued, ending with Officer Lee shooting Mr. Martinez. The administratrix of Mr. Martinez's estate filed a lawsuit under 42 U.S.C. § 1983, alleging violations of the Fourth Amendment due to unlawful arrest and excessive force.The United States District Court for the Northern District of Oklahoma initially granted summary judgment in favor of Officer Lee. However, upon appeal, the Tenth Circuit reversed this decision, stating that the district court had failed to consider the plaintiff's version of events, which could constitute an unlawful arrest and excessive force. The case was remanded to the district court to determine if these findings would clearly establish a constitutional violation. The district court concluded that they would and denied summary judgment to Officer Lee, leading to the current appeal.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court held that Officer Lee lacked qualified immunity on the claims of unlawful arrest and excessive force. The court determined that no reasonable officer could have perceived probable cause for the arrest based on the plaintiff's version of events, which included no threats or violent actions by Mr. Martinez. Additionally, the court found that the use of deadly force was clearly established as unconstitutional in situations where the suspect posed no immediate threat. Consequently, the Tenth Circuit affirmed the district court's denial of summary judgment for Officer Lee. View "Ibarra v. Lee" on Justia Law

David Walton, a Wisconsin prisoner, filed a lawsuit under 42 U.S.C. § 1983 against Ashley Nehls, a prison nurse, alleging that she violated his Eighth Amendment rights by engaging in a sexual relationship with him. Walton testified that the relationship was consensual. The district court granted summary judgment for Nehls, reasoning that a consensual sexual relationship does not constitute cruel or unusual punishment under the Eighth Amendment.The United States District Court for the Eastern District of Wisconsin reviewed the case and entered summary judgment in favor of Nehls. The court concluded that Walton's testimony about the consensual nature of the relationship meant that it could not be considered a violation of the Eighth Amendment. Walton appealed the decision, urging the appellate court to adopt a legal presumption that any sexual activity between a prisoner and a prison official is nonconsensual and violates the Constitution unless the prison official can show an absence of coercion.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The Seventh Circuit acknowledged the power dynamics between prisoners and prison officials and the evolving standards of decency, noting that all 50 states have criminalized sexual conduct between prison officials and prisoners. However, the court found that even if it applied the presumption of nonconsent, the evidence in the record established that the relationship between Walton and Nehls lacked any coercive factors. Therefore, the court affirmed the district court's entry of summary judgment for Nehls, leaving the broader legal question of adopting a presumption of nonconsent for another day. View "Walton v Nehls" on Justia Law

Sonya Kenette Brown, a City Council member in Albion, Michigan, was prosecuted for allegedly violating a City Charter provision that prohibits council members from directing the appointment or removal of city employees. Brown claimed that her political opponents on the City Council engaged in retaliatory prosecution and arrest, malicious prosecution, and conspiracy to violate her civil rights. She also challenged the constitutionality of the City Charter provision.The United States District Court for the Western District of Michigan dismissed Brown's claims of retaliatory prosecution and arrest, malicious prosecution, and conspiracy, finding that there was probable cause for her prosecution based on her Facebook messages. The court also granted summary judgment to the defendants on Brown's claim that the City Charter provision was unconstitutional.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of Brown's claims, agreeing that there was probable cause for her prosecution. The court found that Brown's Facebook messages provided sufficient evidence to believe she had violated the City Charter by directing the removal of a city employee. The court also held that the City Charter provision was not unconstitutionally vague or overbroad, as it provided clear standards and did not prohibit a substantial amount of protected speech.The Sixth Circuit concluded that Brown's claims failed because she could not demonstrate an absence of probable cause, and the City Charter provision was constitutionally valid. The court affirmed the district court's judgment in favor of the defendants. View "Brown v. City of Albion, Mich." on Justia Law

Lathfield Investments, LLC, Lathfield Holdings, LLC, and Lathfield Partners, LLC (collectively, "Lathfield") own three commercial buildings in Lathrup Village, Michigan, rented to various commercial tenants. The City of Lathrup Village and its Downtown Development Authority (collectively, the "City") require landlords to obtain a rental license and list each tenant's name and principal business. Lathfield applied for a landlord rental license in July 2020 but did not list the required tenant information, leading to the denial of their application and their tenants' business license applications. Lathfield sued the City, alleging unlawful compulsion to apply for unnecessary licenses and make unnecessary property improvements, bringing eleven claims, nine against the City.The United States District Court for the Eastern District of Michigan granted summary judgment to the City on all nine claims. Lathfield appealed, arguing that the City improperly required site plan approval, violated due process and equal protection rights, and engaged in inverse condemnation, among other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Lathfield's request for declaratory relief regarding site plan approval was moot since the site plan process was already completed. The court also found that Lathfield was required to obtain a general business license under the City Code and that the City Code's tenant registration requirement applied to Lathfield. The court rejected Lathfield's due process claims, noting that the City’s adoption of the Michigan Building Code was a legislative act not subject to procedural due process requirements. The court also dismissed Lathfield's equal protection claim due to a lack of evidence of differential treatment and found no basis for the Contracts Clause claim under 42 U.S.C. § 1983. Lastly, the court concluded that Lathfield failed to establish an inverse condemnation claim or a civil conspiracy. View "Lathfield Investments, LLC v. City of Lathrup Village, Mich." on Justia Law

Jeffrey G. Hutchinson was convicted of murdering his girlfriend Renee Flaherty and her three children in 1998. After an argument with Renee, Hutchinson drank heavily, returned to her home with a shotgun, and killed Renee and two of her children with single shots to the head. He then shot the third child, Geoffrey, twice, killing him. Hutchinson called 911, admitting to the shootings, and was found by police with gunshot residue on his hands and body tissue from Geoffrey on his leg. He was charged with four counts of first-degree murder and sentenced to death for the murders of the three children.Hutchinson's convictions and death sentences were affirmed on direct appeal by the Florida Supreme Court. He filed multiple postconviction motions, all of which were denied. His initial state postconviction motion and successive motions were also denied, as were his federal habeas petitions. His fourth successive postconviction motion, filed after the Governor signed a death warrant, was denied by the circuit court without an evidentiary hearing.The Supreme Court of Florida reviewed Hutchinson's appeal of the denial of his fourth successive postconviction motion and his habeas corpus petition. The court affirmed the circuit court's denial, rejecting Hutchinson's claims that the warrant period violated his constitutional rights, that the warrant selection process was arbitrary, and that his execution would be cruel and unusual punishment. The court also denied his habeas claims, including his argument that Atkins v. Virginia should extend to individuals with neurocognitive disorders and his challenge to the heinous, atrocious, or cruel (HAC) aggravator. The court denied Hutchinson's requests for a stay and oral argument, and ordered the mandate to issue immediately. View "Hutchinson v. State" on Justia Law

Three criminal defendants in San Francisco, on behalf of themselves and a putative class, challenged the constitutionality of the San Francisco Sheriff's Office (SFSO) Pre-Trial Electronic Monitoring program (PTEM). They specifically contested Rule 5, which requires enrollees to submit to warrantless searches, and Rule 11, which allows SFSO to share participants’ location data with other law enforcement agencies without a warrant and to retain the data. The plaintiffs were divided into two subclasses: those enrolled in the program before May 2023 ("original rules subclass") and those enrolled after May 2023 ("revised rules subclass").The United States District Court for the Northern District of California granted a preliminary injunction in favor of the plaintiffs, finding that the Program Rules likely violated their rights under the United States and California constitutions. The court enjoined the enforcement of the challenged Program Rules for both subclasses. The Sheriff appealed the injunction, particularly the prohibition on enforcing the location sharing provision.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that it had jurisdiction over the appeals and that abstention was not warranted. The court found that the plaintiffs were unlikely to succeed on their facial challenges to Rule 11’s location sharing requirement for the revised rules subclass. The court determined that the Superior Court exercises a core judicial power in imposing PTEM and that the Sheriff’s program does not create separation-of-powers issues. The court also found that the location sharing provision was reasonable under the Fourth Amendment and the California Constitution when ordered by the Superior Court following an individualized determination. The court vacated the preliminary injunction as to the revised rules subclass but affirmed it for the original rules subclass due to the lack of a clear record that location sharing was a condition of PTEM enrollment. The court also granted the Sheriff’s motion to stay the district court’s subsequent order enforcing the preliminary injunction. View "SIMON V. CITY AND COUNTY OF SAN FRANCISCO" on Justia Law

A class of incarcerated juvenile offenders in Florida, all sentenced to life in prison with the possibility of parole under a now-defunct sentencing scheme, sued the Commissioners of the Florida Commission on Offender Review. They claimed that the parole system violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Fourteenth Amendment's due process rights. The plaintiffs argued that the parole system did not provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation.The United States District Court for the Middle District of Florida granted summary judgment to the Commissioners, dismissing the plaintiffs' claims. The court found that Florida's parole system did not violate the Eighth Amendment or the Fourteenth Amendment's Due Process Clause. The plaintiffs appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Florida's parole system does not violate the Eighth Amendment for either homicide or non-homicide juvenile offenders. For homicide offenders, the system is not a sham and provides a genuine possibility of parole, satisfying the requirements set forth in Miller v. Alabama. For non-homicide offenders, the system offers a meaningful opportunity for release based on demonstrated maturity and rehabilitation, as required by Graham v. Florida.Regarding the due process claim, the court concluded that the plaintiffs did not have a constitutionally protected liberty interest in parole under either state law or the Eighth Amendment. Therefore, their procedural due process claim failed. The Eleventh Circuit affirmed the district court's grant of summary judgment to the Commissioners. View "Howard v. Coonrod" on Justia Law

Matthew Morrison was convicted of a sexually violent offense and sentenced to prison. Before his release, the Santa Clara County District Attorney filed a petition to commit him as a sexually violent predator under the Sexually Violent Predator Act (SVPA). The trial court found the petition true, declared Morrison a sexually violent predator, and committed him to the State Department of State Hospitals for an indeterminate term.Morrison appealed, arguing that the trial court violated his constitutional rights by not personally advising him of his right to a jury trial and securing a personal waiver of that right. He claimed that the SVPA’s failure to require a personal jury trial advisement and waiver, unlike other civil commitment statutes, violated the constitutional equal protection guarantee.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court determined that Morrison’s equal protection challenge was subject to rational basis review. Since Morrison did not raise the issue in the trial court, the appellate court conditionally affirmed the commitment order and remanded the matter to allow Morrison to raise his equal protection claim before the trial court. The appellate court provided guidance on the principles the trial court should apply when resolving Morrison’s constitutional claim. View "P. v. Morrison" on Justia Law

David Knellinger and Robert Storey discovered that the state of Colorado had taken possession of their property under the Revised Uniform Unclaimed Property Act (RUUPA). They filed a lawsuit under 42 U.S.C. § 1983, claiming that Colorado's unclaimed property scheme violated the Takings Clause of the Fifth Amendment. The plaintiffs alleged that Colorado took their property for public use without just compensation and did not provide them with notice or compensation.The United States District Court for the District of Colorado dismissed the plaintiffs' claims for lack of standing. The court found that Knellinger and Storey failed to sufficiently allege ownership of the property at issue, partly because they did not file an administrative claim to establish ownership as required by RUUPA. The district court also dismissed the plaintiffs' equitable claims, concluding that § 1983 provided an adequate basis for obtaining just compensation.The United States Court of Appeals for the Tenth Circuit reviewed the case and determined that the district court erred in dismissing the plaintiffs' claims for monetary relief. The appellate court held that Knellinger and Storey had plausibly alleged that Colorado took their property for public use without just compensation, which is sufficient to confer standing. The court emphasized that property owners need not file administrative claims with Colorado before suing for just compensation under the Takings Clause. However, the appellate court affirmed the district court's dismissal of the plaintiffs' equitable claims, as § 1983 provides an adequate remedy for obtaining just compensation.The Tenth Circuit reversed the district court's dismissal of the plaintiffs' damages claims and remanded the case for further proceedings consistent with its opinion. View "Knellinger v. Young" on Justia Law