Justia Civil Rights Opinion Summaries

In 2007, Crawley and two codefendants invaded a home and attacked and robbed a man they believed to be a drug dealer. A woman and two children were also in the home. Crawley pleaded guilty to conspiracy to commit Hobbs Act robbery, 18 U.S.C. 1951 and using, carrying, and brandishing firearms during and in relation to a crime of violence and a drug trafficking crime, 18 U.S.C. 924(c). Other counts were dismissed, including for attempting to possess with intent to distribute a Schedule II Controlled Substance, 21 U.S.C. 846. The court sentenced Crawley to 150 months on Count One and 84 months on Count Three, to run consecutively. Crawley later unsuccessfully moved to vacate his sentence under 28 U.S.C. 2255.The Fourth Circuit subsequently permitted Crawley to file a second 2255 motion challenging his 924(c) conviction and sentence in light of the Supreme Court’s 2015 holding that the residual clause of the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(2)(B)(ii), is unconstitutionally vague. While Crawley’s motion was pending, the Fourth Circuit concluded that conspiracy to commit Hobbs Act robbery is not a crime of violence under section 924(c)’s force clause and the crime of violence definition in section 924(c)’s residual clause is unconstitutionally vague. The Fourth Circuit affirmed that Crawley’s 924(c) conviction remained valid because it was predicated on the use, carrying, and brandishing of firearms during the charged drug trafficking crime. View "United States v. Crawley" on Justia Law

The Fifth Circuit withdrew its prior opinion on April 21, 2021 and substituted the following opinion.After petitioner was convicted of capital murder in Texas and sentenced to death, on federal habeas corpus review, the district court granted him relief. The Fifth Circuit court then affirmed the grant of relief, petitioner was retried, and petitioner was resentenced to death. Petitioner again sought federal habeas corpus relief under 28 U.S.C. 2254, but the district court denied relief on all claims.The Fifth Circuit denied petitioner a certificate of appealability (COA) on the issue of whether the admission of testimony from a defense expert was fruit of the poisonous tree where petitioner has not identified any clearly established Supreme Court precedent extending Harrison v. United States, 392 U.S. 219 (1968), to his incriminating statements to his own expert; whether the State's peremptory strike of a black juror violated petitioner's right to a fair and impartial trial under Batson v. Kentucky, 476 U.S. 79 (1986), where the prosecutor gave six reasons for striking the juror and petitioner failed to present clear and convincing evidence to rebut the determination as objectively unreasonable; whether the State suppressed evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), where he failed to establish cause for defaulting his Brady claim; and (4) whether petitioner received ineffective assistance of trial, appellate, and habeas counsel under Strickland v. Washington, 466 U.S. 668 (1984), where he failed to prove either the deficiency prong and/or prejudice prong of Strickland and thus could not overcome the procedural bar. View "Guidry v. Lumpkin" on Justia Law

Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging that the officer unlawfully arrested him and used excessive force during the arrest. Plaintiff's claims stemmed from an incident where the officer issued tickets to him for illegal parking and resisting arrest. Plaintiff pleaded guilty to illegal parking by signing the ticket at the police station, and the City later dismissed the charge of resisting arrest.The Eighth Circuit affirmed the denial of summary judgment on plaintiff's unlawful arrest claim where there is a genuine dispute of material fact about whether the officer entered plaintiff's home without a warrant to effect the arrest. In regard to plaintiff's separate Fourth Amendment claim premised on the alleged use of excessive force, the court concluded that the officer is entitled to qualified immunity because an officer could reasonably believe that plaintiff was resisting arrest. The court explained that, under the circumstances, it was not clearly established at the time that officers were forbidden to use force, including a taser, to arrest a suspect who resisted, ignored instructions, and walked away from the officer. The court noted that any damages that plaintiff suffered because of his arrest are subsumed within his unlawful arrest claim. Therefore, even without a freestanding claim for use of excessive force, plaintiff may recover any damages that he suffered from the officer's use of a taser if plaintiff succeeds on his claim alleging unlawful arrest based on an unjustified entry into the home. View "Gerling v. Waite" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Walmart in an action brought by plaintiff, alleging age discrimination under the Iowa Civil Rights Act (ICRA). The court assumed that plaintiff met his prima facie burden under the McDonnell Douglas standard, but concluded that Walmart offered a legitimate, non-discriminatory reason for terminating his employment, the violation of the Hazardous Materials Endorsement policy while on a Third Written (a policy meaning he could be fired if disciplined again). The court also concluded that plaintiff's evidence was insufficient to allow a reasonable juror to find that Walmart's proffered reason for firing him was pretextual. View "Gardner v. Wal-Mart Stores, Inc." on Justia Law

B.L. failed to make her school’s varsity cheerleading squad. While visiting a store over the weekend, B.L. posted two images on Snapchat, a social media smartphone application that allows users to share temporary images with selected friends. B.L.’s posts expressed frustration with the school and the cheerleading squad; one contained vulgar language and gestures. When school officials learned of the posts, they suspended B.L. from the junior varsity cheerleading squad for the upcoming year.The Third Circuit and Supreme Court affirmed a district court injunction, ordering the school to reinstate B. L. to the cheerleading team. Schools have a special interest in regulating on-campus student speech that “materially disrupts classwork or involves substantial disorder or invasion of the rights of others.” When that speech takes place off-campus, circumstances that may implicate a school’s regulatory interests include serious bullying or harassment; threats aimed at teachers or other students; failure to follow rules concerning lessons and homework, the use of computers, or participation in online school activities; and breaches of school security devices. However, courts must be more skeptical of a school’s efforts to regulate off-campus speech.B.L.’s posts did not involve features that would place them outside the First Amendment’s ordinary protection; they appeared outside of school hours from a location outside the school and did not identify the school or target any member of the school community with vulgar or abusive language. Her audience consisted of her private circle of Snapchat friends. B.L. spoke under circumstances where the school did not stand in loco parentis. The school has presented no evidence of any general effort to prevent students from using vulgarity outside the classroom. The school’s interest in preventing disruption is not supported by the record. View "Mahanoy Area School District v. B. L." on Justia Law

Lange drove by a California highway patrol officer, playing loud music and honking his horn. The officer followed Lange and soon turned on his overhead lights to signal Lange to pull over. Rather than stopping, Lange drove a short distance to his driveway and entered his attached garage. Without obtaining a warrant, the officer followed Lange into the garage, questioned him, and, after observing signs of intoxication, put him through field sobriety tests. Charged with misdemeanor DUI, Lange moved to suppress the evidence obtained after the officer entered his garage. California courts rejected his Fourth Amendment arguments.The Supreme Court vacated. Under the Fourth Amendment, the pursuit of a fleeing misdemeanor suspect does not always justify a warrantless entry into a home. Precedent favors a case-by-case assessment of exigency when deciding whether a suspected misdemeanant’s flight justifies a warrantless home entry. Such exigencies may exist when an officer must act to prevent imminent injury, the destruction of evidence, or a suspect’s escape. Misdemeanors may be minor. When a minor offense (and no flight) is involved, police officers do not usually face the kind of emergency that can justify a warrantless home entry. Adding a suspect’s flight does not change the situation enough to justify a categorical rule. When the totality of circumstances (including the flight itself) show an emergency—a need to act before it is possible to get a warrant—the police may act without waiting. Common law afforded the home strong protection from government intrusion and did not include a categorical rule allowing warrantless home entry when a suspected misdemeanant flees. View "Lange v. California" on Justia Law

Plaintiffs filed a putative class action challenging New York City's Third Party Transfer (TPT) Program, through which the City initiates in rem foreclosure proceedings against tax-delinquent properties and, following a foreclosure judgment, transfers ownership of the properties to third party partners who develop and manage the properties. Plaintiffs alleged federal constitutional and state law claims stemming from the transfer of their properties through the TPT. The district court dismissed the complaint.The Second Circuit concluded that plaintiffs lack standing to seek injunctive and declaratory relief; the TIA is not directly applicable to plaintiffs' claims and the district court exceeded its discretion in concluding that comity bars their claims; and the Rooker-Feldman doctrine does not bar plaintiffs' equal protection and due process claims, or their second takings claim – that their property was taken for a public purpose without just compensation – to the extent that for each of those claims, they seek only the value of their lost property in excess of the amount owed in taxes. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. The court also vacated and remanded the district court's decision not to exercise supplemental jurisdiction over plaintiffs' state law claims. View "Dorce v. City of New York" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment in favor of Microsoft on plaintiff's claims under the Americans with Disabilities Act (ADA) for failure to accommodate, discrimination, and creation of a hostile work environment. Plaintiff's claims stemmed from his efforts to obtain accommodations for his Autism Spectrum Disorder while employed as an account technology strategist and an Enterprise Architect (EA) at Microsoft.In regard to plaintiff's claim for failure to accommodate, the court concluded that plaintiff's requests for individuals to assist him with translating verbal information into written materials, recording meeting notes, and performing administrative tasks were unreasonable because they would exempt him from performing essential functions. Consequently, plaintiff is not a qualified person under the ADA. Furthermore, there is no genuine dispute of material fact that plaintiff's performance as an EA at this point was deficient and thus there was no genuine dispute of material fact that he could have performed EA essential functions without all of his requested accommodations. The court also concluded that, even if plaintiff were a qualified person under the ADA, he also fails to create a genuine issue of material fact as to whether Microsoft failed to negotiate in a good-faith manner. The court explained that, because Microsoft had the "ultimate discretion to choose between effective accommodations," it was justified in placing plaintiff on job reassignment over his objections. In this case, the record demonstrates that plaintiff, not Microsoft, was responsible for the breakdown of the interactive process seeking reasonable accommodation in refusing to indicate interest in any vacant position.In regard to plaintiff's discrimination claim, the court concluded that plaintiff cannot establish a prima facie discrimination claim for the same reason his failure-to-accommodate claim fails—he is not a qualified individual under the ADA. Even if he were qualified, plaintiff was not subject to an adverse employment decision. Finally, in regard to plaintiff's hostile-work-environment claim, the court concluded that none of the evidence plaintiff relies on indicates that he was subject to harassment pervasive or severe enough to alter the conditions of his employment. Furthermore, plaintiff's placement on job reassignment is not evidence of a hostile work environment. View "Thompson v. Microsoft Corp." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress his text message conversation with an undercover federal agent and to dismiss the charge of patronizing prostitution, holding that the district court did not err.From his cell phone, Defendant responded to an ad placed in a warrantless internet sting operation. Thereafter, Defendant engaged in a text message conversation with "Lily," an undercover law enforcement officer. Defendant was subsequently charged with patronizing prostitution, a misdemeanor. Defendant filed a motion to suppress his text conversation with "Lily" and for dismissal of the case due to a lack of evidence. The district court denied the motions, and Defendant entered a conditional guilty plea. The Supreme Court affirmed, holding that the warrantless use of a cloaked law enforcement officer under a fake internet advertisement for sexual services and the responsive text message conversation did not intrude upon an objectively reasonable expectation of privacy and therefore did not effect a constitutional search in violation of Defendant's right to privacy under Mont. Const. art. II, 10-11. View "State v. Staker" on Justia Law

Olvera’s conviction stems from the 2000, death of Stropes during a gang-related drive-by shooting in East Moline. Olvera’s codefendant, Delgado, fired the shot. Olvera was the driver of the vehicle and did not fire any shots that evening. Delgado pleaded guilty to murder. At Olvera’s trial, his girlfriend and others testified that the shooting arose out of an incident at a party. Olvera unsuccessfully sought state court post-conviction review, claiming that his trial counsel had failed to “contact or call” several witnesses “whose testimony would have been of significant benefit to him.”The Seventh Circuit affirmed the denial of Olvera’s petition for federal habeas relief. The state court’s articulation of the Strickland standard was not contrary to the Supreme Court’s clearly established law. The state court did not unreasonably apply Strickland when it concluded that affidavits submitted by the potential witnesses identified by Olvera failed to demonstrate prejudice or failed to demonstrate deficient performance. The court noted the overwhelming evidence supporting the state’s accountability theory and precluding Olvera’s claim of self-defense that was “left untouched.” View "Olvera v. Gomez" on Justia Law