Justia Civil Rights Opinion Summaries

After Jerome Goode led police on a twenty-five-mile car chase, the chase ended in his death and the deaths of passengers Lavoy Steed and Leon Haywood. Steed's next friend filed a 42 U.S.C. 1983 action against Missouri State Troopers Fowler and Ashby, alleging that the traffic stop that precipitated the chase and an attempt to halt Goode's vehicle with spike strips were unconstitutional seizures in violation of the Fourth Amendment.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the troopers, concluding that Trooper Fowler had probable cause to stop the vehicle where dashcam footage shows the vehicle going close to ninety miles per hour. Even assuming that the trooper misinterpreted the speed reading, he would still be entitled to qualified immunity because he had at least arguable probable cause to believe the vehicle was speeding. The court also concluded that the record clearly establishes that the troopers did not apply physical force by trying to use the spike strips, and thus there was no seizure. View "Steed v. Missouri State Highway Patrol" on Justia Law

The Eighth Circuit affirmed the district court's denial of the officers' motion for summary judgment in a 42 U.S.C. 1983 action brought by plaintiff, who had been arrested at a protest, alleging violations of his First and Fourth Amendment rights and conspiracy to violate his rights, and under Missouri state law. Plaintiff and his wife were documentary filmmakers who were covering protests in downtown St. Louis, Missouri, following Officer Jason Stockley's acquittal of charges arising from the death of Anthony Lamar Smith.The court concluded that, viewing the evidence in the light most favorable to plaintiff, a reasonable jury could conclude that Officer Biggins used excessive force during plaintiff's arrest, that he acted with an "actual intent to cause injury" to plaintiff, and that his use of excessive force was done in retaliation for plaintiff's First Amendment activity. Therefore, the district court did not err in denying summary judgment based on qualified immunity to Officer Biggins on plaintiff's First and Fourth Amendment claims, nor did the district court err in denying summary judgment based on official immunity to Officer Biggins on plaintiff's state law assault and battery claim. The court declined to consider the officers' argument concerning application of the intracorporate conspiracy doctrine because it was raised for the first time on appeal. View "Burbridge v. Biggins" on Justia Law

The Supreme Court reversed the judgment of the district court concluding that Employer discriminated against Employee by firing him when he sought a reasonable accommodation for a disability, holding that Defendants were entitled to judgment as a matter of law on each of Employee's disability discrimination claims except his claims for failure to accommodate and retaliation based on his request for a sign language interpreter.Employee, who had a preexisting hearing impairment, continued to work while rehabilitating from a workplace injury, and Employer assisted the rehabilitation by providing light-duty work. When a disagreement arose as to whether Employee was entitled to a specific work restriction, Employee was fired. A jury awarded Employee damages after finding that Employer discriminated against him when Employee sought a reasonable accommodation for a disability. The Supreme Court reversed, holding (1) to the extent Plaintiff's disability claims were based on the workplace injury, Plaintiff's failure to identify a job he could perform apart from the temporary light-duty work defeated his claims; and (2) Employer was entitled to a new trial on Employee's disability claims stemming from his request for a sign language interpreter. View "Rumsey v. Woodgrain Millwork, Inc." on Justia Law

The Fourth Circuit affirmed the district court's grant of a declaratory judgment holding that the clerks from two Virginia courts, that failed to make newly filed civil complaints timely available to the press and public, violated the First Amendment right of access to such documents.As a preliminary matter, the court concluded that this case is not moot where, absent the relief Courthouse News sought, nothing bars the clerks from reverting to the allegedly unconstitutional rates of access in the future; the district court did not abuse its discretion in denying the clerks' motion to abstain; and the district court did not abuse its discretion in denying the clerks' motion to dismiss for misjoinder.On the merits, the court applied the experience and logic test to Courthouse News' First Amendment right of access claim, concluding that the experience prong supports a First Amendment right of access to civil complaints, even before any judicial action in the case, and that public access to complaints logically plays a positive role in the functioning of the judicial process. Therefore, the press and public enjoy a First Amendment right of access to newly filed civil complaints. The court agreed with the district court's determination that the clerks violated Courthouse News' right of access to newly filed civil complaints. View "Courthouse News Service v. Schaefer" on Justia Law

Plaintiffs moved to enjoin implementation of the Aerial Investigation Research (AIR) program, a first-of-its-kind aerial surveillance program operated by the Baltimore Police Department and Commissioner Michael Harrison. While appeal was pending, the program completed its pilot run and the program was not renewed. After deleting the bulk of the AIR data, defendants moved to dismiss the appeal as moot.On rehearing en banc, the court concluded that the appeal presents a live controversy and is not moot. Plaintiffs sought to enjoin defendants' access to any data collected by the AIR program, and defendants retain the data that proved fruitful. In this case, plaintiffs have a concrete, legally cognizable interest in freezing the police department's access to images, which were obtained only by recording plaintiffs' movements and in which they may still appear.On the merits, the court concluded that plaintiffs are likely to succeed on the merits of their Fourth Amendment claim and the remaining Winter factors counsel in favor of preliminary relief. The court applied Carpenter v. United States, 138 S. Ct. 2206 (2018), concluding that the AIR program enables police to deduce from the whole of individuals' movements, and thus accessing its data is a search, and its warrantless operation violates the Fourth Amendment. The court reversed the denial of plaintiffs' motion for a preliminary injunction and remanded for further proceedings. View "Leaders of a Beautiful Struggle v. Baltimore Police Department" on Justia Law

The Supreme Court affirmed the judgment of the superior court convicting Defendant of five counts related to conduct stemming from a drive-by shooting, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) there was no need to reach the merits of Defendant's belatedly raised double jeopardy contention; (2) the trial justice did not err in denying Defendant's motion to suppress an eyewitness identification; (3) the trial justice did not err by summarily denying Defendant's motion to recuse; (4) Defendant was not denied his constitutional right to self-representation; and (5) Defendant's remaining arguments were not properly preserved for appellate review. View "State v. Segrain" on Justia Law

The Supreme Court affirmed the sentence of death that was imposed at Defendant's resentencing for the first-degree murder of Seath Jackson, holding that Defendant's claims of error were unavailing.The Supreme Court previously affirmed Defendant's conviction for first-degree murder with a firearm but vacated his sentence of death and remanded for a new penalty phase based on Hurst v. State, 202 So. 3d 40 (Fla. 2016). After a new penalty phase, the judge again imposed a sentence of death. The Supreme Court affirmed, holding (1) the State was not precluded from seeking the death penalty; (2) Defendant's argument that the court erred in allowing evidence of post-death acts was not adequately preserved for review; (3) the circuit court did not abuse its discretion in assigning little or no weight to mental mitigation factors; (4) the circuit court properly considered Defendant's age and certain other mitigating circumstances; and (5) the death sentence was not disproportionate. View "Bargo v. State" on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding the order of the municipal court granting Defendant's motion to suppress, holding that the police officer's investigatory stop of Defendant was reasonable and thus did not violate the Fourth Amendment.At issue was whether the officer had reasonable suspicion to briefly detain Defendant in order to confirm or dispel an unidentified witness's claim that Defendant was operating a motor vehicle while intoxicated. The trial court granted Defendant's motion to suppress. The court of appeals affirmed, holding that the officer lacked the reasonable suspicion necessary to effectuate a lawful investigatory stop because the anonymous tip lacked sufficient indicia of reliability and because there was no evidence of erratic driving by Defendant prior to the stop. The Supreme Court reversed, holding that the officer had reasonable suspicion to investigate whether Defendant was driving while drunk based on the unidentified customer's tip and the officer's own partial corroboration of that tip. View "State v. Tidwell" on Justia Law

Plaintiff appealed the dismissal of his 42 U.S.C. 1983 claims based on allegations that defendants illegally extradited him from Pennsylvania to Louisiana and impermissibly extended his state sentence by thirty years. Plaintiff's claims arose from a records clerk's reversion of his release date to the 2052 date, rather than the 2023 date, on the grounds that he had stopped serving his state sentence when he escaped from prison and that his state and federal sentences were intended to run consecutively.The Fifth Circuit affirmed the district court's dismissal of plaintiff's sentence-based claims, but reversed and remanded with respect to the extradition-based claims. The court held that Heck v. Humphrey, 512 U.S. 477 (1994), does not present a jurisdictional hurdle that would require a remand of this case to state court. The court explained that Heck implicates a plaintiff's ability to state a claim, not whether the court has jurisdiction over that claim. As to plaintiff's claim regarding his sentence enhancement, the court concluded that a claim for speedier release is actionable by writ of habeas corpus, and a section 1983 damages action predicated on the sentence calculation issue is barred by Heck because success on that claim would necessarily invalidate the duration of his incarceration. The court also concluded that the district court never analyzed whether plaintiff's extradition-based claims were barred by Heck, and the district court should have considered whether his extradition-based claims survived Heck in the first instance. Furthermore, the district court should consider the qualified immunity, absolute immunity, and limitations ruling issues on remand. The court vacated in part and remanded for further proceedings. View "Colvin v. LeBlanc" on Justia Law

Five former employees of national security agencies who, during their employment, had clearances for access to classified and sensitive information, filed suit against the CIA, the Department of Defense, the National Security Agency, and the Office of the Director of National Intelligence. They facially challenged the agencies’ requirements that current and former employees give the agencies prepublication review of certain materials that they intend to publish to allow the agencies to redact information that is classified or otherwise sensitive to national security. They alleged that the agencies’ regimes “fail to provide former government employees with fair notice of what they must submit,” “invest executive officers with sweeping discretion to suppress speech[,] and fail to include procedural safeguards designed to avoid the dangers of a censorship system.”The Fourth Circuit affirmed the dismissal of the suit, holding that the prepublication review regimes were “reasonable” measures to protect sensitive information and did not violate the plaintiffs’ First Amendment rights. The regimes were not unduly vague under the Fifth Amendment; they adequately informed authors of the types of materials they must submit and established for agency reviewers the kinds of information that can be redacted. View "Edgar v. Haines" on Justia Law