Justia Civil Rights Opinion Summaries

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

Charitable organizations soliciting funds in California generally must register with the Attorney General and renew their registrations annually by filing copies of their IRS Form 990, on which tax-exempt organizations provide the names and addresses of their major donors. Two tax-exempt charities that solicit contributions in California renewed their registrations and filed redacted Form 990s to preserve their donors’ anonymity. The Attorney General threatened the charities with the suspension of their registrations and fines. The charities alleged that the compelled disclosure requirement violated their First Amendment rights and the rights of their donors. The Ninth Circuit ruled in favor of the Attorney General.The Supreme Court reversed. California’s disclosure requirement is facially invalid because it burdens donors’ First Amendment rights and is not narrowly tailored to an important government interest. Compelled disclosure of affiliation with groups engaged in advocacy may constitute as effective a restraint on freedom of association as other forms of governmental action. Exacting scrutiny requires that a government-mandated disclosure regime be narrowly tailored to the government’s asserted interest, even if it is not the least restrictive means of achieving that end.A dramatic mismatch exists between the Attorney General's asserted interest and the disclosure regime. While California’s interests in preventing charitable fraud and self-dealing are important, the enormous amount of sensitive information collected through the disclosures does not form an integral part of California’s fraud detection efforts. California does not rely on those disclosures to initiate investigations. There is no evidence that alternative means of obtaining the information, such as a subpoena or audit letter, are inefficient and ineffective by comparison. Mere administrative convenience does not “reflect the seriousness of the actual burden” that the disclosure requirement imposes on donors’ association rights. It does not make a difference if there is no public disclosure, if some donors do not mind having their identities revealed, or if the relevant donor information is already disclosed to the IRS. View "Americans for Prosperity Foundation v. Bonta" on Justia Law

Arizona voters may cast their ballots on election day in person at a traditional precinct or a “voting center” in their county of residence, may cast an “early ballot” by mail, or may vote in person at an early voting location in each county. Arizonans who vote in person on election day in a county that uses the precinct system must vote in the precinct to which they are assigned based on their address; if a voter votes in the wrong precinct, the vote is not counted. For Arizonans who vote early by mail, Arizona HB 2023 makes it a crime for any person other than a postal worker, an elections official, or a voter’s caregiver, family member, or household member to knowingly collect an early ballot.A suit under section 2 of the Voting Rights Act of 1965, 52 U.S.C. 10301, challenged Arizona’s refusal to count ballots cast in the wrong precinct and its ballot-collection restriction. The Ninth Circuit invalidated both restrictions. The Supreme Court reversed, characterizing Arizona's restrictions as “generally applicable time, place, or manner” voting rules and declining to apply the disparate-impact model to displace “the totality of circumstances.” The Court also rejected a “least-restrictive means” analysis as having “the potential to invalidate just about any voting rule.”The core of section 2(b) is “equally open” voting. Any circumstance that bears on whether voting is equally open and affords equal “opportunity” may be considered. Voting necessarily requires some effort and compliance with rules. Having to identify one’s polling place and travel there to vote does not exceed the “usual burdens of voting.” A rule’s impact on members of different racial or ethnic groups is important but the existence of some disparity does not necessarily mean that a system is not equally open. A procedure that apparently works for 98% or more of voters to whom it applies, minority and non-minority alike, is unlikely to render a system unequally open. The degree to which a voting rule departs from standard practices is relevant. The policy of not counting out-of-precinct ballots is widespread. The strength of the state interests served by a challenged rule is important. Precinct-based voting helps to distribute voters more evenly, can put polling places closer to voter residences, and helps to ensure that each voter receives a ballot that lists only the relevant candidates and public questions. Courts must consider the state’s entire system of voting; a burden associated with one voting option must be evaluated in the context of the other available means.HB 2023 also passes muster. Arizonans can submit early ballots in several ways. Even if the plaintiffs could demonstrate a disparate burden, Arizona’s “compelling interest in preserving the integrity of its election procedures” would suffice under section 2. Third-party ballot collection can lead to pressure and intimidation and a state may take action to prevent election fraud without waiting for it to occur within its own borders. View "Brnovich v. Democratic National Committee" on Justia Law

The Supreme Court affirmed Defendant's convictions of aggravated murder with an escaping-detection specification, kidnapping, felonious assault, possessing criminal tools, tampering with evidence, and having weapons while under a disability and Defendant's sentence of death, holding that there was no error in proceedings below.Specifically, the Supreme Court held (1) the State proved beyond a reasonable doubt that Defendant committed the offenses of aggravated murder and kidnapping; (2) the trial court did not deny Defendant's right to a fair trial by denying his motion for a new venire; (3) trial counsel did not provide ineffective assistance; (4) the trial court did not err in admitting evidence of other crimes, wrongs, or acts; (5) there was no error in the sentencing opinion; and (6) there was no other error in Defendant's sentencing. View "State v. Worley" on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition for a writ of habeas corpus under 28 U.S.C. 2254, as amended by the Antiterrorism and Effective Death Penalty Act (AEDPA), holding that the district court did not err in denying the petition.In his habeas petition, Petitioner alleged that the trial court violated his constitutional rights to a complete defense and to have effective assistance of counsel. The district court denied the petition. The First Circuit affirmed, holding (1) the exclusion of certain medical evidence, even if error, was harmless beyond a reasonable doubt; and (2) trial counsel was not constitutionally deficient for not consulting or calling a child abuse expert who could testify to the effects of Munchausen Syndrome by Proxy on fathers like Petitioner. View "Strickland v. Goguen" on Justia Law

The First Circuit affirmed the drug conspiracy and distribution convictions of five members of a drug trafficking organization, holding that none of the issues raised by the five defendants translated into reversible error warranting vacatur of their convictions or sentences.Fifty-five individuals were indicted on charges of conspiracy to distribute heroin, cocaine, cocaine base, marijuana, and prescription pills. By the time a jury trial began most of the defendants had pleaded guilty. Five of the defendants who were ultimately convicted appealed their convictions, and some of them appealed their sentences. The defendants were Joel Rivera-Alejandro, Carlos Rivera-Alejandro, Juan Rivera-George, Suanette Ramos- Gonzalez, and Idalia Maldonado-Pena. The First Circuit affirmed the judgments in their entirety, holding that there was no reversible error in this case. View "United States v. Maldonado-Pena" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) and the circuit court's order denying Defendant's motion for a new trial, holding that the cumulative impact of misconduct on the part of the prosecutor deprived Defendant of a fair trial and was not harmless beyond a reasonable doubt.Specifically, the Supreme Court held (1) at trial, the prosecutor introduced to the jury incriminatory statements allegedly made by Defendant without previously disclosing them to the defense during discovery in violation of Haw. R. Pen. P. 16(b)(1); (2) the prosecutor introduced statements that were incriminating to Defendant that were allegedly made by the complaining witness despite the court's motion in limine ruling barring their introduction; (3) the prosecutor engaged in improper and unnecessarily lurid questioning of defense witnesses to inflame the jury's passions; and (4) the circuit court erred in denying Defendant's motion for a new trial based on prosecutorial misconduct, and the ICA erred in concluding that the prosecutor's misconduct was harmless. View "State v. Williams" on Justia Law

An abortion facility (RHS) and its owner filed suit against the Attorney General of Alabama and the District Attorney of Montgomery County, challenging some of the amendments to Alabama's Parental Consent Act, Ala. Code 26-21-4, which regulates an unemancipated minor's ability to obtain an abortion. Ruling on cross-motions for judgment on the pleadings, the district court held that some of the challenged provisions were unconstitutional, severed those provisions from the rest of the Act, and entered a declaratory judgment that rendered the severed provisions unenforceable.The Eleventh Circuit concluded that the district court correctly held that RHS had Article III standing to challenge Alabama's Parental Consent Act. In this case, plaintiffs have satisfied the injury-in-fact requirement and they have demonstrated causation and redressability. The court also concluded that the district court correctly held that the Attorney General and the District Attorney are proper defendants under Ex parte Young. The court explained that the criminal-enforcement link here establishes the necessary connection between defendants and the challenged provisions. The court stated that Ex parte Young provides an avenue for a civil lawsuit so plaintiffs do not need to subject themselves to criminal prosecution to challenge unconstitutional laws. That civil avenue is particularly important here, where the law involves the inherently serious time-sensitive issue of minors' access to abortion and violating the law could cause medical professionals to lose their licenses.On the merits, the court agreed with the district court that several provisions of the Act create an undue burden under Whole Woman's Health v. Hellerstedt, 136 S. Ct. 2292, 2309 (2016), and Planned Parenthood of S.E. Pa. v. Casey, 505 U.S. 833, 877 (1992). The court agreed with the district court that the Act constitutes an undue burden because it places a substantial obstacle on a "large fraction" of unemancipated minors who seek to obtain a court order authorizing an abortion without the consent of their parent or guardian. The court considered the benefits and burdens of the challenged regulation, concluding that although the state has an interest in providing guidance and assistance to minors who seek an abortion without parental consent, the challenged provisions provide, if anything, marginal benefit. Instead, the provisions created substantial obstacles and were therefore impermissible means of serving legitimate ends. The court was confident that the Act as amended creates an undue burden under Whole Woman's Health by placing a substantial obstacle each year for a handful of unemancipated minors who would seek to obtain a judicial bypass from the parental/guardian consent requirements of the Act. For these minors, the Act would either (a) unduly interfere with the minors' ability to demonstrate maturity or best interest by adding additional (and possibly adversarial parties) in the bypass proceeding, or (b) deter them from trying to obtain a court order through a judicial bypass proceeding. Accordingly, the court affirmed the district court's judgment. View "Reproductive Health Services v. Bailey" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction court denying Appellant's petition for post-conviction relief raising challenges to the effectiveness or his trial and appellate counsel, holding that Appellant's claims failed, and he was not entitled to relief.Appellant was convicted of three counts of murder and three counts of criminal recklessness and was sentenced to death. Appellant later filed a petition for post-conviction relief, alleging several claims of ineffective assistance of trial counsel. The post-conviction court denied the petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief on his claims that his trial counsel were constitutionally ineffective at all phases of Appellant's trial; (2) appellate counsel were not ineffective for failing to raise fundamental-error challenges on direct appeal concerning certain instructions; and (3) Appellant was not entitled to relief on his freestanding challenges to the post-conviction court's rulings. View "Isom v. State" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against a police officer and the City of Ferguson, alleging violations of his First, Fourth, and Fourteenth Amendment rights. Plaintiff's claims stemmed from nine citations he received from the officer at a park. The district court found that the officer was not entitled to qualified immunity and thus denied defendants' joint motion for summary judgment.After determining that it had jurisdiction, the Eighth Circuit vacated the district court's order denying defendants' joint motion for summary judgment and remanded so that the district court may further consider the officer's asserted entitlement to qualified immunity. In this case, when discussing plaintiff's Fourth Amendment seizure claim, the district court commenced its analysis by citing case law that outlined the general legal standards for probable cause and reasonable suspicion, but it largely failed to apply this case law, or more analogous cases, to plaintiff's version of the facts. Furthermore, the district court failed to conduct the materiality inquiry by framing legal questions as factual ones; the court was unable to discern whether the district court applied the clearly established prong at all, much less conducted a "thorough determination;" the district court defined the relevant law at too high a level of generality to conduct a proper clearly established analysis; and the district court's excessive force analysis fails to identify a specific right or factually analogous cases. Finally, the court dismissed the City's appeal for lack of jurisdiction. View "Watson v. Boyd" on Justia Law