Justia Civil Rights Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court granting Defendants' motion to dismiss Plaintiff's tortious interference with a prospective economic advantage claim, holding that the First Amendment of the United States Constitution and N.C. Const. art. I, 12 explicitly protect petitioning activity, including Defendants' speech in this case.Plaintiff brought this complaint alleging that, by virtue of intentional and malicious misrepresentations made to a town, Defendants tortiously interfered with Plaintiff's prospective economic advantage by inducing a third party not to perform the purchase of certain property. Plaintiff's suit was based on Defendants' presentation at certain rezoning hearings. Defendants moved to dismiss the complaint for failure to state a claim, asserting that they were immune from liability because their statements to the town were constitutionally protected petitioning activity. The trial court granted the motion to dismiss. The court of appeals reversed. The Supreme Court court reversed, holding that Defendants' petitioning was protected by the First Amendment and Article I, Section 12. View "Cheryl Lloyd Humphrey Land Investment Co., LLC v. Resco Products, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals ordering a new trial in this case on the grounds that the prosecutor's commentary on Defendant's decision to plead not guilty was so unfair it violated Defendant's due process rights, holding that the prosecutor's comments did not so prejudice Defendant so as to warrant a new trial.Defendant was found guilty of several offenses after a jury trial. On appeal, Defendant argued that the trial court committed reversible error in failing to intervene ex mero motu when the prosecutor made improper remarks about Defendant's decision to plead not guilty during closing arguments. The court of appeals agreed and ordered a new trial. The Supreme Court reversed, holding that Defendant failed to show that he was prejudiced as a result of the prosecutor's improper closing arguments. View "State v. Goins" on Justia Law

The Second Circuit affirmed the district court's grant of a petition for habeas relief to petitioner, who was convicted by a jury in state court of first degree manslaughter. The court concluded that the admission of the autopsy report at petitioner's trial through a surrogate witness was an unreasonable application of clearly established Supreme Court precedent. See Crawford v. Washington, 541 U.S. 36, 40 (2004); Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009); and Bullcoming v. New Mexico, 564 U.S. 647 (2011). Furthermore, the unreasonably erroneous admission of the autopsy report was not harmless where the report was the strongest evidence in the State's case and was not cumulative of other inculpatory evidence connecting petitioner to the victim's death. View "Garlick v. Lee" on Justia Law

The Supreme Court vacated the portions of the emergency order issued by Janel Heinrich, in her capacity as a local health officer of Public Health of Madison and Dane County, restricting or prohibiting in-person instruction in all schools in Dane County for grades 3-12, holding that those portions were unlawful and unenforceable and are hereby vacated.The disputed order was issued in an effort to decrease the spread of COVID-19. Petitioners - students - brought three cases challenging Heinrich's authority to issue the emergency order, contending that the order exceeded her statutory authority under Minn. Stat. 252.03, violated Petitioners' fundamental right to the free exercise of religioun under Wis. Const. art. I, 18, and violated parents' fundamental right to direct the upbringing and education of their children under Wis. Const. art. I, 1. The Supreme Court consolidated the cases and held (1) local health officers do not have the statutory power to close schools under section 252.03; and (2) the order infringed Petitioners' fundamental right to the free exercise of religion guaranteed in the Wisconsin Constitution. View "St. Ambrose Academy, Inc. v. Parisi" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the Commission in an action brought by plaintiff, alleging that the Commission discriminated against her in violation of Title VII. Plaintiff argues that her suspension, probation, and termination were discrimination based on race and national origin. The Commission stated that plaintiff's termination was due to failure to comply with requests to provide company passwords to agency programs and documents. The court concluded that plaintiff did not show evidence of pretext or that she could satisfy the McDonnell Douglas burden-shifting framework before the district court or in her opening brief, and thus she cannot prove a circumstantial case of discrimination. View "Towery v. Mississippi County Arkansas Economic Opportunity Commission, Inc." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful distribution of heroin as a subsequent offender and unlawful possession of heroin with intent to distribute as a subsequent offender, holding that the superior court did not err by denying Defendant's motion to suppress and that there was no other error.In his suppression motion, Defendant sought to suppress evidence found during a warrantless search of a motor vehicle. The superior court denied the motion to suppress. The Supreme Judicial Court affirmed the denial of the suppression motion and Defendant's convictions, holding (1) the police had probable cause to search the vehicle, and there was no error in the denial of the motion to suppress; (2) the trial judge erred in allowing the admission of an in-court identification made by a police officer, but the error did not prejudice Defendant; and (3) there was no substantial risk of a miscarriage of justice as to the jury instructions on possession and distribution of narcotics. View "Commonwealth v. Ortiz" on Justia Law

In this appeal from various orders regarding Defendant's pretrial detention status the Supreme Judicial Court vacated the decision of the single justice concluding that no due process violation occurred regarding one case and ruled that the other case was moot, holding that remand was required for a determination as to whether Defendant's continued pretrial confinement violates due process.Defendant had been held in pretrial detention for more than eighteen months on charges arising out of the Chelsea Division and the Lynn Division of the District Court Department. At the time of this opinion, Defendant had been held for over a year beyond his initial trial dates. Defendant was eventually acquitted of the charges in the Chelsea case. In the Lynn case, Defendant's trial was delayed due to the COVID-19 pandemic. At issue was whether the prolonged detention violated Defendant's due process rights. The Supreme Judicial Court held (1) in analyzing whether a defendant's pretrial detention violates due process this opinion contains a procedural framework; (2) because Defendant was acquitted in the Chelsea case, that case was moot; and (3) as to the Lynn case, the matter must be remanded for further proceedings. View "Mushwaalakbar v. Commonwealth" on Justia Law

The Supreme Court reversed the order of the trial court suppressing statements made by Defendant during a police interview, holding that the circumstances did not amount to a custodial interrogation.At issue was whether Defendant's freedom of movement was curtailed to a level associated with formal arrest when he had a free-flowing exchange in a detective's personal office. In granting Defendant's motion to suppress the trial court concluded that the circumstances were akin to a custodial interrogation and that the statements were obtained in violation of the Fifth Amendment. The Supreme Court disagreed and reversed the suppression order, holding that the limited curtailment of Defendant's freedom of movement did not amount to a formal arrest. View "State v. Diego" on Justia Law

Inmate Robinson was offered new medication. Unaware of any prescription, he questioned the officer who gave it to him and followed up with the health services manager and others. Despite learning that there was no record of any new prescription for him, Robinson took the medication. Days later, Robinson passed out. A nurse advised him to keep taking the medication. Robinson then was sent to an outside hospital, where doctors surmised that he might be allergic to the medication. The prescription was meant for a different inmate. Robinson sued. The defendants moved for summary judgment; 20 days after his deadline for filing a brief in opposition, Robinson filed a brief to support his own request for summary judgment, supplemented by a proposed statement of facts. He did not respond to the defendants’ statement of facts. The district court granted the defendants summary judgment.The Seventh Circuit affirmed. The district court permissibly applied Eastern District of Wisconsin Local Rule 56(b)(4) to deem the defendants’ facts unopposed, regardless of Robinson’s later filings. Based on those facts, no reasonable jury could find deliberate indifference to a serious medical risk. Nor could a jury conclude that the health‐services manager violated his constitutional rights by failing to intervene. Robinson’s state‐law negligence claims were barred by Wisconsin’s notice‐of‐claim statute. The defendants were not entitled to summary judgment based only on Robinson's failure to timely respond. View "Robinson v. Waterman" on Justia Law

After plaintiff was attacked by his cellmate, he filed suit against the United States under the Federal Tort Claims Act (FTCA) and five prison employees under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388, 91 S. Ct. 1999 (1971). Plaintiff alleged that prison officials negligently assigned the cellmate to plaintiff's cell and that their conduct also violated his Eighth Amendment rights.The Eleventh Circuit affirmed the district court's dismissal of plaintiff's FTCA claim against the United States based on the discretionary function exception to the FTCA's waiver of sovereign immunity. The court explained that inmate-classification and housing-placement decisions fall squarely within the discretionary function exception. The court also affirmed the district court's dismissal without prejudice of plaintiff's Bivens claim against the prison employees for failure to exhaust his administrative remedies. View "Shivers v. United States" on Justia Law