Justia Civil Rights Opinion Summaries

Ademiju immigrated to the U.S. in 2001 and had a green card. In 2011, he became involved in a scheme to defraud Medicare. He pled guilty to healthcare fraud, 18 U.S.C. 1347, and stipulated to a $1.5 million loss amount, acknowledging that “pleading guilty may have consequences with respect to his immigration status” and that he “affirms that he wants to plead guilty … even if the consequence is his automatic removal.” At sentencing, Ademiju personally acknowledged that his ability to stay in this country was not assured. His counsel told the court, “I’m not an immigration specialist … But it’s my understanding that … any sentence of less than one year … he would be at least eligible for a waiver.” Apparently, no one knew that statement was incorrect. The district court sentenced Ademiju to 11 months’ imprisonment plus $1.5 million in restitution.Ademiju was released from federal prison and transferred into ICE custody; he retained an immigration attorney who informed him that his offense of conviction and the stipulated loss amount subjected him to mandatory deportation. Ademiju filed a 28 U.S.C. 2255 motion to vacate his conviction because his attorney provided ineffective assistance of counsel, arguing that the statute of limitations should be tolled because he received incorrect advice from an attorney about his options for recourse within the limitations period and could not have discovered the problem himself due to the inadequacy of his prison’s law library. The Seventh Circuit affirmed the dismissal of his motion; Ademiju has not met the high standard for equitable tolling. View "Ademiju v. United States" on Justia Law

Petitioner, an Arkansas prisoner under a sentence of death for capital murder, petitioned for habeas corpus in the federal district court. In a previous appeal, the Eighth Circuit affirmed the dismissal of several claims, but remanded for further proceedings on four claims alleging ineffective assistance of counsel under the Sixth Amendment. The court also remanded for further proceedings on petitioner's claim that he is ineligible for the death penalty, due to intellectual disability, under the Eighth Amendment and the rule of Atkins v. Virginia, 536 U.S. 304 (2002). On remand, the district court rejected the Atkins claim, but granted relief on two of the ineffective-assistance claims and set aside petitioner's sentence. Both parties appealed.The Eighth Circuit reversed the grant of relief based on alleged ineffective assistance of counsel. In this case, petitioner's federal claim that trial counsel failed to obtain a timely psychological evaluation of him was presented in the state postconviction court and defaulted when he declined to appeal on that ground. As such, the procedural default cannot be excused based on alleged ineffectiveness of state postconviction counsel. Likewise, the third claim cannot be excused based on alleged ineffectiveness of state postconviction counsel. The court affirmed the denial of relief under the Eighth Amendment, concluding that the district court considered the Atkins claim under both the DSM-IV-TR and DSM-V criteria, reached the same conclusion based on each, and thus there was no legal error. The court rejected petitioner's remaining challenges to the district court's analysis of his intellectual functioning, including additional indicia of intellectual disability, expert and witness testimony, adaptive strengths and weaknesses, and adaptive functioning deficits. View "Sasser v. Payne" on Justia Law

Petitioners filed suit seeking injunctive relief, alleging that the denials of their requests for tuition funding violated their rights to the free exercise of religion under the First Amendment. Under Vermont's Town Tuition Program (TTP), sending districts pay tuition to independent schools on behalf of high-school-aged students residing in the districts. The district court found that the school districts—endeavoring to comply with a state constitutional provision—denied petitioners' funding requests solely because of the religious status of petitioners' chosen school. Following Supreme Court precedent, the district court ruled that the exclusion of petitioners from the TTP violated the First Amendment, and the district court granted a limited preliminary injunction in petitioners' favor. Because respondents wanted to develop new criteria for TTP eligibility that would satisfy the state constitution, the district court enjoined the school districts from continuing to exclude petitioners from the TTP based solely on the religious status of petitioners' chosen school. However, the district court declined to mandate that the districts allow petitioners to participate in the TTP until the case was resolved. Petitioners appealed and moved for an emergency injunction pending appeal that would prohibit the school districts from continuing to deny their TTP funding requests.The Second Circuit construed petitioners' motion as a petition for a writ of mandamus directing the district court to amend its preliminary injunction. In February 2021, the court granted the petition for writ of mandamus because petitioners clearly had a right to the relief they requested and mandamus was justified to enable them to obtain that relief. In this opinion, the court explained the reasons for its order granting the writ, concluding that petitioners have no other adequate means to attain the relief they desire; the district court was wrong to allow the school districts to continue to withhold TTP funds from petitioners while the districts developed new restrictions and safeguards; and the writ is appropriate where petitioners have been deprived of a public benefit as a result of the state's and the school districts' decades-long policy of unconstitutional religious discrimination. View "A.H. v. French" on Justia Law

The Supreme Judicial Court vacated the decision of the superior court judge allowing Defendant's motion to suppress, holding that Defendant enjoyed no reasonable expectation of privacy in the text messages sent by him that were stored on a cellular telephone belonging to, and possessed by, another person.Defendant and six codefendants were indicted on charges of trafficking in cocaine, conspiracy to violate drug laws, and conspiracy to commit money laundering. The charges stemmed from an investigation originating, in part, from evidence acquired during a search of a codefendant's cell phone. The owner of the telephone filed a motion to suppress evidence obtained as a result of the search of his phone, including the contents of text messages sent by Defendant. Defendant moved to join the motion. The Commonwealth opposed the motion, arguing that Defendant lacked standing to challenge the search. The judge ruled that Defendant had standing and allowed him to join the motion. The Supreme Judicial Court reversed, holding that Defendant could not challenge the reasonableness of the search because he lacked a reasonable expectation of privacy in the sent text messages. View "Commonwealth v. Delgado-Rivera" on Justia Law

Brown was shot and killed at a Philadelphia playground. Several witness accounts implicated Baxter and McBride as the shooters. Baxter was convicted of first-degree murder, criminal conspiracy to engage in murder, and first-degree possession of an instrument of a crime with intent to employ it criminally.The trial judge had described the Commonwealth’s burden of proof, “beyond a reasonable doubt,” “the highest standard,” stating that the Commonwealth “is not required to meet some mathematical certainty” or “to demonstrate the complete impossibility of innocence.” A “doubt that would cause a reasonably careful and sensible person to pause, to hesitate, to refrain from acting upon a matter of the highest importance to your own affairs or to your own interests” "If you were advised by your loved one’s physician that that loved one had a life-threatening illness and that the only protocol was a surgery, very likely you would ask for a second opinion.... You’d probably start researching the illness ... if you’re like me, call everybody you know in medicine... At some moment, however, you’re going to be called upon to make a decision.... If you go forward, it’s because you have moved beyond all reasonable doubt. "[R]easonable doubt must be a real doubt” and “may not be a doubt that is imagined or manufactured to avoid carrying out an unpleasant responsibility.”Baxter's federal habeas corpus petition argued for the first time that his trial counsel was ineffective for failing to object to the reasonable doubt instruction. The Third Circuit affirmed the denial of relief. The reasonable doubt instruction did not prejudice Baxter, given the evidence of his guilt. View "Baxter v. Superintendent Coal Township SCI" on Justia Law

Plaintiffs, ten former University of Minnesota football players, appealed the dismissal of their Amended Complaint against the University and two University officials, asserting a variety of claims arising out of the University’s investigation of a complaint of sexual assault and harassment by another student, Jane Doe. Plaintiffs are African-American males who alleged that the University targeted them on the basis of their sex and race and unfairly punished them in response to Jane's accusations. The district court dismissed all claims.The Eighth Circuit concluded that plaintiffs' complaint alleged a number of circumstances which, taken together, are sufficient to support a plausible claim that the University discriminated against plaintiffs on the basis of sex. In this case, plaintiffs alleged that the University was biased against them because of external pressures from the campus community and the federal government, and plaintiffs alleged historical facts that reinforce the inference of bias in this specific proceeding. Therefore, the court reversed the district court's dismissal of plaintiffs' Title IX discrimination claims.The court affirmed the district court's dismissal of the Title IX claims for retaliation where plaintiffs did not plausibly allege that their request for a Student Sexual Misconduct Subcommittee hearing was tantamount to a complaint of sex discrimination, and even if a request for a hearing made by a person accused of sexual misconduct could amount to protected activity, the Amended Complaint did not plausibly plead prima facie retaliation claims. The court also affirmed the dismissal of the race discrimination claims where the Amended Complaint did not plausibly allege a comparator similarly situated to plaintiffs in all relevant aspects; affirmed the dismissal of plaintiffs' due process claims where plaintiffs failed to exhaust the existing procedures for appealing the University's disciplinary decision and failed to allege prehearing deprivations or deprivation of protected property or liberty interests in violation of due process; and affirmed the dismissal of the contract and negligence claims on Eleventh Amendment grounds. View "John Does 1-2 v. Regents of the University of Minnesota" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's Wyo. R. App. P. 21 motion asserting that his trial counsel provided ineffective assistance when he failed to raise a challenge under Batson v. Kentucky, 476 U.S. 79 (1986), holding that the district court did not err.Defendant was convicted of conspiracy to commit aggravated robbery. During trial, the State used two peremptory challenge to strike the only minority jurors in the venire. Defendant's counsel failed to raise a Batson challenge to the State's use of peremptory challenges. The Supreme Court affirmed, holding (1) there is no direct appeal of a Batson claim if it was not raised in the trial court; (2) the failure to raise a Batson challenge is not usually structural error when it is brought in the context of an ineffective assistance of counsel claim; (3) the district court correctly ruled that trial counsel was not ineffective for failing to raise a Batson challenge; and (4) the district court had not duty sua sponte to raise Batson on its own under the facts of this case. View "Yazzie v. State" on Justia Law

The Ninth Circuit reversed the district court's grant of summary judgment for CoreCivic in an action brought by plaintiff under Nevada state law for torts related to his year-long detention in a private prison without a court hearing. The district court granted CoreCivic's summary judgment motion on the ground that CoreCivic did not cause plaintiff's prolonged detention.The panel concluded that a jury could reasonably find that CoreCivic's actions caused plaintiff's prolonged detention. In this case, a rational jury could find that, in failing to notify the Marshals of plaintiff's detention and in dissuading and preventing him from seeking other help, CoreCivic was a cause of his pre-hearing detention as required to establish claims for false imprisonment, negligence, and intentional infliction of emotional distress. The panel also concluded that a jury could find that CoreCivic breached a duty to plaintiff, and thus plaintiff has established triable issues as to his negligence claim. Furthermore, a jury could reasonably find CoreCivic's actions extreme and outrageous, and thus plaintiff has established triable issues as to his claim for intentional infliction of emotional distress. View "Rivera v. Corrections Corporation of America" on Justia Law

An Oklahoma court ordered Boyd to stay away from his ex-wife and his son, surrender his firearms, and undergo a mental health evaluation. After his arrest in Pennsylvania with a loaded handgun, Boyd was convicted of possessing a firearm while subject to a domestic violence protective order, 18 U.S.C. 922(g)(8).The Third Circuit affirmed. After Boyd’s trial, the Supreme Court issued “Rehaif,” requiring that the government show both that a defendant was subject to a qualifying protective order at the time he possessed a gun and that he knew about the protective order. The district court had not instructed the jury on this knowledge element, but the error was harmless, given the overwhelming evidence of Boyd’s knowledge, including his own admissions in a letter to the court. The admission into evidence of statements that Boyd made about harming the Trump family did not contribute to the verdict, leaving any error harmless. Statements in the prosecution’s closing argument that accused the defense of “misleading” the jury, were also harmless given the context, jury instructions, and weight of the evidence.Section 922(g)(8) does not violate the Second Amendment as applied to Boyd and others whose protective orders were issued without an explicit finding that they pose a credible threat to their intimate partners or their children. The application of section 922(g)(8) survives heightened scrutiny; the statute is substantially related to the goal of reducing domestic violence, an indisputably important state interest. View "United States v. Boyd" on Justia Law

The Eighth Circuit affirmed the district court's sua sponte grant of judgment as a matter of law to defendants in an action brought by plaintiff against prison officials, alleging that they failed to protect him from his fellow inmates after he was labeled a snitch.Even assuming the court agreed with plaintiff that Federal Rule of Civil Procedure 50(a) requires a motion, the court did not think that requirement is clear or obvious under its case law. The court concluded that the district court did not err in directing a verdict in favor of the five defendants who were not on the Classification Committee. In this case, plaintiff cannot show that defendants acted with deliberate indifference by entrusting the decision to the Classification Committee—the prison's selected arbitrator. The court explained that, even if they disagreed with the choice, there is nothing to suggest that four of the defendants had any power to circumvent the ruling of the Classification Committee and it was a close call with the fifth defendant. Finally, the court concluded that the district court did not abuse its discretion by denying plaintiff's motions for continuance by ensuring an expeditious disposition of the case and while affording significant time to allow plaintiff to prepare. View "Axelson v. Watson" on Justia Law