Justia Civil Rights Opinion Summaries

In 1996, Reeves and some friends went “looking for some robberies ” but their car broke down. Johnson offered to tow their vehicle. After they arrived, Reeves shot Johnson and directed the others to get his money. Reeves bragged that the murder would earn him a gang tattoo; at a party, Reeves mocked pumping a shotgun and the way that Johnson died. Alabama charged Reeves with murder. His appointed attorneys explored possible intellectual disability. They obtained Reeves’ educational, medical, and correctional records and funding to hire a neuropsychologist (Dr.Goff). Reeves was within the “borderline” range of intelligence but had been denied special education services. A psychologist evaluated Reeves and opined that he was not intellectually disabled. Reeves’ attorneys apparently elected to pursue other mitigation strategies. The jury recommended a death sentence.Reeves unsuccessfully sought state post-conviction relief, alleging that he was intellectually disabled or that counsel should have hired Dr. Goff to develop mitigation. Dr. Goff testified that Reeves was intellectually disabled. The state’s expert administered his own evaluation and concluded that Reeves was not intellectually disabled, noting that Reeves had a leadership role in a drug-dealing group. Although his lawyers were available, Reeves did not call them to testify. The Court of Criminal Appeals affirmed. The federal district court denied habeas relief. The Eleventh Circuit reversed in part, finding that Reeves's lawyers were constitutionally deficient for not developing evidence of intellectual disability and that this failure might have changed the outcome of the trial. The Supreme Court reversed. The Alabama court did not violate clearly established federal law in rejecting Reeves’ claim. Counsel’s strategic decisions are entitled to a “strong presumption” of reasonableness. The analysis is “doubly deferential” when a state court has decided that counsel performed adequately. Despite Reeves’ allegations about his lawyers, he offered no evidence from them. Counsel’s efforts to collect Reeves’ records and obtain funding hardly indicates neglect and disinterest. The Alabama court conducted a case-specific analysis and reasonably concluded that the incomplete evidentiary record doomed Reeves’ belated efforts to second-guess his attorneys. The Eleventh Circuit recharacterized its analysis as a “categorical rule” that any prisoner will always lose if he fails to question trial counsel regarding his reasoning. View "Dunn v. Reeves" on Justia Law

Plaintiff filed suit challenging the constitutionality of Arkansas' limits on which candidates can appear on its general-election ballot, Ark. Code 7-7-101. After the district court entered judgment upholding the challenged provisions, plaintiff appealed. While the appeal was pending, the 2020 general election came and went.The Eighth Circuit dismissed plaintiff's appeal as moot, concluding that the "capable-of-repetition-yet-evading-judicial-review" exception to mootness did not apply. The court explained that plaintiff's interest in this case was predicated on his status as an Independent candidate; without such a candidacy, the challenged provisions do not apply to him. However, plaintiff's 2020 Independent candidacy has ended and he has not indicated whether he intends to run as an Independent again. Therefore, this case is no longer "live." Furthermore, plaintiff has failed to show that he is reasonably likely to be subject to the challenged statutory provisions again. View "Whitfield v. Thurston" on Justia Law

Plaintiff filed suit against defendant, asserting claims of First Amendment retaliation and Fourth Amendment unreasonable seizure under 42 U.S.C. 1983 and claims under the Arkansas Civil Rights Act (ACRA), for violating rights secured by Article II, 6, 8, 9, and 15 of the Arkansas Constitution. Plaintiff's claims stems from his arrest by defendant for disorderly conduct after plaintiff yelled an expletive at him from a moving vehicle.The Eighth Circuit affirmed the district court's judgment, concluding that the district court did not err by dismissing plaintiff's ACRA claim because plaintiff presented no evidence on summary judgment that defendant acted maliciously; the district court did not err in regards to its punitive damages rulings where plaintiff failed to produce sufficient evidence that defendant's conduct warranted the imposition of punitive damages, and plaintiff's trial testimony failed to establish facts meeting the punitive-damages standard; the district court did not abuse its discretion in denying plaintiff's motion for a new trial; and the district court did not abuse its discretion in awarding attorney's fees in this nominal damages case. View "Thurairajah v. Cross" on Justia Law

Plaintiff filed suit against the City, alleging retaliation under Labor Code section 1102.5. The City asked the trial court to dismiss plaintiff's action for failure to exhaust available administrative remedies, but the trial court concluded that an appeal to the HR Commission was unnecessary. After the case proceeded to trial, the jury found for plaintiff and awarded him about $4 million, including $2 million in past noneconomic damages and $1.5 million in future noneconomic damages. The trial court subsequently denied the City's motion for a new trial.The Court of Appeal concluded that the involvement of plaintiff's direct superior in the underlying dispute, on one hand, and his expected role in deciding plaintiff's appeal, on the other, violated the requirements of due process and therefore excused plaintiff from proceeding with his administrative appeal. The court also found no reversible evidentiary error by the trial court. However, the court agreed with the City that the $3.5 million noneconomic damages award -- comprising $2 million in past and $1.5 million in future noneconomic damages -- was so excessive as to suggest it resulted from passion or prejudice. Accordingly, the court vacated the awards for past and future noneconomic damages and remanded for a new trial on these issues, unless plaintiff accepts a reduction of the awards to $1 million and $100,000, respectively. The court affirmed in all other respects. View "Briley v. City of West Covina" on Justia Law

Huelsman, age 64, had symptoms of paranoia and bipolar disorder. In the midst of a crisis during which he expressed delusional thoughts and a desire to commit suicide, his wife, Cheryl, a nurse, called their daughter and urged her to call 911. Clermont County Deputies Gregory and Walsh responded, aware of Huelsman’s mental health and that there might be guns in the house. Gregory called off the paramedics who had also responded, calling the matter a domestic dispute. Gregory spoke with both Cheryl who expressed her desperate fear that her husband would commit suicide, and Huelsman, whom Gregory considered to be lucid. Cheryl repeatedly exhorted Gregory not to leave Huelsman alone, but the Deputy left him inside the home, unattended, for about nine minutes while calling for a Mobile Crisis team. Huelsman committed suicide, using a gun.In a suit alleging civil rights violations, 42 U.S.C. 1983; denial of public services under the Americans with Disabilities Act (ADA); and Ohio law torts, the district court granted the defendants summary judgment. The Sixth Circuit affirmed as to the section 1983 and ADA claims and vacated as to the state law claims. The deputies were entitled to qualified immunity; it is not clear they had sufficient warning of the possible unconstitutionality of their conduct. Huelsman was not denied the benefits of Clermont County’s services for purposes of the ADA. View "Wilson v. Gregory" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal in this case involving allegations of active gang participation and gang enhancements attached to other offenses, holding that the commission of two or more predicate offenses must be proven by independent admissible evidence, and such proof may not be established solely by the testimony of an expert who has no personal knowledge of facts otherwise necessary to satisfy the prosecution's burden.The two defendants in this case were charged with two counts of attempted murder, assault with a firearm, and active street gang participation. Gang and firearm enhancements were attached to the charges. The first trial ended when the jury hung on almost all charges, but a second jury convicted Defendants of the remaining allegations. The court of appeal reversed the active gang participation and enhancement allegations, as well as Defendant's firearm enhancements attached to those allegations, and otherwise affirmed, holding that some of an expert's testimony constituted inadmissible hearsay. The Supreme Court affirmed, holding (1) the jury was permitted to improperly rely on hearsay to conclude that the predicate offenses had been proven and that Defendants acted with intent to benefit a gang when they committed the crimes with which they were charged; and (2) the error was not harmless. View "People v. Valencia" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of kidnapping and killing Shirley and Andrew Demko after burglarizing and robbing their home, holding that there was no error in the proceedings below.On appeal, Defendant raised numerous allegations of error both during the guilt phase and the penalty phase. The Supreme Court rejected the claims and affirmed the judgment in its entirety, holding (1) the trial court did not err in denying Defendant's Batson/Wheeler motion upon finding that the prosecutor did not make a prima facie showing that the prosecutor exercised a peremptory challenge in a discriminatory manner; (2) assuming, without deciding, that the trial court erred in admitting statements that Defendant identified as implicating prior burglaries, any error was harmless as a matter of law; and (3) there were no penalty phase errors and no cumulative prejudice to consider. View "People v. Battle" on Justia Law

Plaintiff filed suit alleging that he was injured during the course of an arrest made by defendant, an officer, at a college board meeting. After the district court denied defendant's motion for summary judgment based on qualified immunity, defendant filed this interlocutory appeal.The Eighth Circuit dismissed the appeal based on lack of jurisdiction, concluding that material factual disputes that are incapable of being resolved on this record are at the heart of defendant's arguments. The court explained that, in order to reach defendant's "legal argument" that he responded reasonably and did not violate clearly established law, the court would have to exceed its jurisdiction and cast aside the district court's factual findings, analyze the factual record, and resolve genuine factual disputes against the non-moving party. View "Taylor v. Caples" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder but reversed his sentence of death and remanded for the limited purpose of resentencing and a new sentencing order, holding that the trial court improperly relied on facts not in the record in sentencing Defendant to death.Specifically, the Supreme Court held (1) the trial court impermissibly relied on non record evidence from the trial of Defendant's codefendant in finding that Defendant was the shooter in this case and sentencing him to death; and (2) Defendant was not entitled to relief on his remaining claims of error. The Supreme Court remanded the case for the limited purpose of requiring the trial court to perform a new sentencing evaluation and provide a new sentencing order. View "Cruz v. State" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment based on qualified immunity to police officers who shot and killed Travis Stevenson. Stevenson was shot after unsuccessful efforts by police to deescalate a situation where Stevenson repeatedly slammed his vehicle into a police cruiser and a concrete pillar in front of an apartment building while yelling "Kill me!"The court concluded that the district court correctly held, in accordance with precedent, that plaintiffs' excessive-force claim fails as a matter of law. In this case, Stevenson was using his car as a weapon; Stevenson, like the drivers in the court's precedent, exhibited volatile behaviors that contributed to the officers justification in firing to prevent death or great bodily harm; and plaintiffs have not produced any evidence that suggests the officers might have had a reasonable alternative course of action. The court agreed with the district court that plaintiffs forfeited their failure-to-train claim against the sheriff by failing to plead it in their complaint and raising it only in response to the officers' motion for summary judgment. View "Jackson v. Gautreaux" on Justia Law