Justia Civil Rights Opinion Summaries

The Fourth Circuit affirmed the district court's denial of a 28 U.S.C. 2254 petition for habeas relief, finding petitioner's ineffective-assistance claim procedurally barred and his other claims without merit. In this case, a jury found petitioner guilty on two counts of first degree murder and two counts of discharging a firearm into an occupied building resulting in serious bodily injury. Defendant was sentenced to two consecutive life sentences without the possibility of parole for the murder convictions, as well as consecutive terms for the firearm convictions.The court concluded that the state court's determination that the trial court was not disproportionate or arbitrary in excluding expert testimony under Federal Rule of Evidence 403 was not an unreasonable application of clearly established federal law. Because petitioner has not established that an exception applies to excuse his procedural default, the court declined to reach the merits of his ineffective-assistance claim. In doing so, the court also found that the district court did not abuse its discretion by not granting petitioner an evidentiary hearing on this claim. The court rejected petitioner's claim, pursuant to Pena-Rodriguez v. Colorado, 137 S. Ct. 855 (2017), that the jury's verdict resulted from racial animus. The court first determined that no clearly established law when the state post-conviction court rejected petitioner's claim provided a racial-animus exception to the no-impeachment rule. The court then determined that the state court's resolution of petitioner's claim reasonably applied the law that was clearly established at that time. Furthermore, Teague v. Lane, 489 U.S. 288, 310 (1989), provides an independent barrier to petitioner's claims. View "Richardson v. Kornegay" on Justia Law

The Ninth Circuit affirmed the district court's denial of injunctive relief and dismissal of state and federal claims in an action brought by Slidewaters LLC, challenging the State of Washington's imposition of COVID-19 restrictions prohibiting the waterpark from operating during 2020 and imposing capacity limits in 2021.The panel concluded that defendants have the authority under Washington law to impose the restrictions and that doing so does not violate Slidewaters' asserted rights under the U.S. Constitution. In this case, the governor had the lawful authority under Revised Code of Washington 43.06.010(12) to issue Proclamation 20-05, because the pandemic was both a public disorder and a disaster affecting life and health in Washington. Furthermore, the State Department of Labor and Industries, in promulgating an emergency rule as part of the state's efforts to curb the pandemic, Washington Administrative Code 296-800-14035, acted within its scope of authority. The panel explained that government regulation does not constitute a violation of constitutional substantive due process rights simply because the businesses or persons to whom the regulation is applied do not agree with the regulation or its application; defendants provided a rational basis for the proclamations and related rules; and the substantive due process rights of Slidewaters, its owners, and its employees are not violated by defendants' actions. Therefore, Slidewaters' application for injunctive relief was properly denied and its claims were properly dismissed. The panel also concluded that the district court did not err in consolidating Slidewaters' motion for preliminary injunction with a hearing on the merits or in reaching Slidewaters' state law claims. View "Slidewaters LLC v. Washington State Department of Labor and Industries" on Justia Law

The Ninth Circuit affirmed the district court's dismissal based on failure to state a claim of a 42 U.S.C. 1983 action brought by plaintiff, alleging that the City violated his Fourth Amendment rights when authorities, without a warrant, searched his massage business.The panel concluded that the Fourth Amendment permitted the warrantless searches of plaintiff's massage business where the California massage industry is a closely regulated industry and the Fourth Amendment's warrantless search exception for administrative searches of businesses applied. The panel applied the factors in New York v. Burger, 482 U.S. 691 (1987), and held that the warrantless inspections were reasonable under the Fourth Amendment because there is no question that curtailing prostitution and human trafficking is a substantial government interest; the warrant exception is necessary to further the regulatory scheme considering the potential ease of concealing violations; and the City ordinance governing massage establishments and the conditional use permit sufficiently restrained the City in both the time and purpose of each inspection. Therefore, the district court properly dismissed plaintiff's Fourth Amendment claims. View "Killgore v. City of South El Monte" on Justia Law

Plaintiff filed suit against Union Pacific in Missouri state court, alleging age discrimination, constructive discharge, and hostile work environment claims under the Missouri Human Rights Act (MHRA). Plaintiff also filed suit against Missouri resident Foster B. McDaniel, claiming that McDaniel aided and abetted Union Pacific in its discriminatory acts. After Union Pacific removed to federal court, the district court granted McDaniel's motion to dismiss and denied plaintiff's motion to remand. The district court later granted Union Pacific's motion for summary judgment on plaintiff's hostile work environment claim.The Eighth Circuit affirmed, concluding that the district court did not err in dismissing McDaniel on the basis of fraudulent joinder because plaintiff's complaint failed to make a colorable claim that McDaniel directly oversaw or was actively involved in discrimination. The court also concluded that the district court did nor err in determining plaintiff did not administratively exhaust his constructive discharge claim. Finally, the court concluded that the district court did not err in granting Union Pacific summary judgment on plaintiff's hostile work environment claim because plaintiff failed to establish age-related harassment sufficiently severe or pervasive to establish the existence of a hostile work environment. View "Henson v. Union Pacific Railroad Co." on Justia Law

The Supreme Court affirmed the judgment of the district court finding Defendant guilty of four counts of sexual abuse of a minor, holding that Defendant knowingly and intelligently waived his Miranda rights and that Defendant did not receive ineffective assistance of counsel.At a hospital, Defendant made incriminating statements to law enforcement officers that he had sexually abused his daughter. Defendant filed a motion to suppress his confessions on the grounds that he was lacking contact with reality when he confessed. The district court denied the motion to suppress, finding that Defendant waived his Miranda rights voluntarily, knowingly, and intelligently. Thereafter, Defendant was convicted. The Supreme Court affirmed, holding (1) Defendant voluntarily waived his Miranda rights; and (2) Defendant's trial counsel provided effective assistance at each phase of Defendant's prosecution. View "Jendresen v. State" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction and sentence for knowing or intentional murder and the denial of his motion for a new trial, holding that there was no error.On appeal, Defendant argued that the trial court erred or abused its discretion in excluding alternative-suspect evidence, failing to provide an adequate explanation in setting the basic sentence, and denying his motion for a new trial based on a juror's statements made after Defendant's conviction. The Supreme Judicial Court affirmed, holding (1) the trial court did not abuse its discretion in excluding alternative-suspect evidence as insufficient to establish a reasonable connection to the crime; (2) the court did not misapply sentencing principles in setting a basic sentence of forty to forty-five years' incarceration; and (3) the court did not err or abuse its discretion in denying Defendant's motion for a new trial. View "State v. Daly" on Justia Law

The Supreme Court affirmed Defendant's judgment of conviction of first-degree murder and sentence of death, holding that Defendant failed to demonstrate error on the part of the trial court.Specifically, the Supreme Court held (1) the trial court did not commit fundamental error by failing to find beyond a reasonable doubt that sufficient aggravating circumstances existed and that those circumstances outweighed the mitigating circumstances; (2) there was no merit to Defendant's challenges to the trial court's handling of mitigating evidence; (3) Defendant's challenge to the constitutionality of the prior-violent-felony aggravator was unavailing; and (4) Defendant's guilty plea was voluntarily and knowingly given. View "Davidson v. State" on Justia Law

The Supreme Court affirmed the order of the trial court summarily dismissing Defendant's successive motion for postconviction relief, holding that the trial court did not err.Defendant pleaded guilty to two counts of first-degree murder and was sentenced to death. The Supreme Court affirmed on direct appeal. When his convictions and sentences had been final for more than twenty-three years Defendant filed the instant successive postconviction motion under Fla. R. Crim. P. 3.851, raising five claims. The trial court summarily dismissed the successive motion. The Supreme Court affirmed, holding (1) the trial court did not err in dismissing four of Defendant's claims as untimely; and (2) Defendant's claim that his death sentences violated the Sixth and Fourteenth Amendments in light of Hurst v. Florida, 577 U.S. 92 (2016), was both untimely and without merit. View "James v. State" on Justia Law

The Second Circuit affirmed the district court's judgment, which (A) declared the Board to be in violation of the Individuals with Disabilities Education Act (IDEA) for denying a free appropriate public education (FAPE) to disabled students between the ages of 21 and 22 while providing a free public education to nondisabled students in the same age range, and (B) permanently enjoined the Board and its successors, employees, and agents, etc., from terminating, on the basis of age, FAPEs for plaintiff class members who have not received a regular high school diploma before they reach the age of 22.The court concluded that the original plaintiff, D.J., had standing to bring the action where D.J. received ten months less of special education than he would have if not for the Board's enforcement of the challenged state regulation, thereby demonstrating injury for purposes of Article III standing. Furthermore, D.J.'s standing was entirely traceable to the Board's enforcement of the regulations at issue and the injury could be redressed by judicial action. On the merits, the court concluded that the district court did not abuse its discretion in interpreting the IDEA term "public education" to encompass free adult education programs offered by the State of Connecticut. The court considered all of the Board's arguments on appeal and found them to be without merit. View "A.R. v. Connecticut State Board of Education" on Justia Law

The First Circuit affirmed the federal convictions and sentences of Defendants - Herzzon Sandoval, Edwin Guzman, Erick Argueta Larios, and Cesar Martinez - stemming from a federal criminal investigation into La Mara Salvatrucha, a transnational criminal organization, in Massachusetts, holding that there was no prejudicial error.Specifically, the First Circuit held (1) Defendants' sufficiency of the evidence challenges to their respective convictions were without merit; (2) there was no merit to Defendants' claims that the district court erred in denying a motion for a continuance due to pretrial publicity or in denying their motion for a mistrial; (3) Defendants' challenges to the court's evidentiary rulings failed; (4) challenges concerning purported misstatements of the evidence in the government's closing argument and purported instructional errors provided no basis for overturning Defendants' convictions; and (5) Defendants' challenges to their sentences failed. View "United States v. Sandoval" on Justia Law