Justia Civil Rights Opinion Summaries

The Supreme Court dismissed Defendant's appeal challenging the factual basis supporting his guilty plea to a drug offense, holding that Defendant failed to establish good cause to pursue a direct appeal as a matter of right.Defendant pled guilty to three drug-related offenses and was sentenced to an indeterminate term of incarceration. On appeal, Defendant argued (1) there was not a factual basis supporting one of his convictions; (2) his counsel provided constitutionally ineffective assistance; and (3) Iowa Code section 814.6 and 814.7 are unconstitutional. The Supreme Court dismissed the appeal, holding (1) section 814.6(1)(a)(3) is constitutional and governs this appeal; and (2) Defendant did not establish good cause to pursue this appeal as a matter of right. View "State v. Treptow" on Justia Law

The Supreme Court declared the issue of partisan gerrymandering a nonjusticiable political question in “Rucho,” in 2019. Michigan had already established its Independent Citizens Redistricting Commission by ballot initiative in the state’s 2018 general election. The Commission is composed of 13 registered voters: eight who affiliate with the state’s two major political parties (four per party) and five who are unaffiliated with those parties, who must satisfy various eligibility criteria designed to ensure that they lack certain political ties. Plaintiffs are Michigan citizens who allege that they are unconstitutionally excluded from serving on the Commission by its eligibility criteria, in violation of the First and Fourteenth Amendments.The Sixth Circuit affirmed the district court’s dismissal of their complaint. Plaintiffs do not have a federal constitutional right to be considered for the Commission. While at least some of the partisan activities enumerated by the eligibility criteria involve the exercise of constitutionally protected interests, Michigan’s compelling interest in cleansing its redistricting process of partisan influence justifies the limited burden imposed by the eligibility criteria. Although claims of unconstitutional partisan gerrymandering may be nonjusticiable, Michigan is free to employ its political process to address the issue head-on. View "Daunt v. Benson" on Justia Law

While plaintiff was incarcerated in a prison medical unit, his doctor reminded him within earshot of others that he had not taken his HIV medication. Plaintiff filed suit alleging that the doctor's conduct violated his Fourteenth Amendment right to privacy and the Health Insurance Portability and Accountability Act of 1996 (HIPAA).The Fourth Circuit affirmed the dismissal of the complaint, rejecting plaintiff's clam that the doctor's statement violated the Fourteenth Amendment. Rather, the court concluded that when the doctor disclosed plaintiff's HIV status, plaintiff was in prison, a place where individuals have a curtailed expectation of privacy. Furthermore, whatever expectations remain fail to include the diagnosis of or medication for HIV, a communicable disease. The court also rejected plaintiff's HIPAA claim because HIPAA does not create a private right of action that plaintiff may avail himself of. View "Payne v. Taslimi" on Justia Law

Plaintiff appealed the district court's dismissal of her complaint against Floridian, in an action alleging that Floridian violated Title III of the Americans with Disabilities Act (ADA) based on barriers to access she encountered at the hotel property (Count I) and deficiencies in its online reservation system (Count II). The district court dismissed Count II for improper claim splitting, given that plaintiff had made a claim in her first lawsuit about Floridian's online reservation system. The district court subsequently dismissed Count I with prejudice for lack of subject matter jurisdiction, concluding that plaintiff did not have standing to seek injunctive relief.The Eleventh Circuit affirmed the district court's dismissal of Count I for lack of standing, except to the extent that the district court dismissed the claim with prejudice. In this case, the totality of relevant facts simply do not support the conclusion that plaintiff faced a real and immediate threat of future discrimination at the Hotel. Therefore, the court remanded for the district court to amend its judgment as to Count I. The court affirmed the district court's dismissal of Count II for claim splitting because Count II and Floridian I arise from the same transaction and are based on facts that are sufficiently related in time, space, origin, and motivation. View "Kennedy v. Floridian Hotel, Inc." on Justia Law

After defendant, a police officer, shot plaintiff in the course of investigating a potential domestic disturbance, plaintiff filed suit under 42 U.S.C. 1983, alleging violations of the Fourth and Fourteenth Amendments.The Eighth Circuit affirmed the district court's denial of defendant's motion for summary judgment on plaintiff's excessive force claim, agreeing with the district court that genuine issues of material fact precluded a grant of qualified immunity. Construing the disputed record in plaintiff's favor, the court concluded that a jury could conclude that no reasonable officer would have thought deadly force was necessary in that moment to protect plaintiff's wife from imminent danger. Furthermore, plaintiff's demeanor and conduct are in dispute. In this case, defendant opened the door and instantaneously shot plaintiff. Therefore, under these circumstances, no reasonable officer would have believed that he had probable cause to use deadly force. Furthermore, plaintiff's right to be free from excessive force under these circumstances was also clearly established at the time. View "Banks v. Hawkins" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that defendant, a police officer, used excessive force against him during a traffic stop. A jury found in favor of plaintiff, awarding compensatory and punitive damages. Defendant appealed.The Eighth Circuit concluded that, viewing the facts in the light most favorable to the verdict, defendant's prolonged use of his taser was not an objectively reasonable use of force. In this case, although plaintiff initially resisted defendant's attempts to remove him from the car, he did not physically hit or verbally threaten defendant. Furthermore, plaintiff, who was 17 years old at the time, posed at most a minimal safety threat to defendant. The court also concluded that plaintiff's right to be free from excessive, prolonged use of a taser was clearly established at the time. Accordingly, the court affirmed the district court's denial of defendant's motion for judgment as a matter of law on the prolonged taser claim.The court rejected defendant's evidentiary claims of error, concluding that the district court did not abuse its discretion in admitting testimony from a vocational rehabilitation expert and testimony from an economist based on the vocational expert's opinion. Finally, the court concluded that the district erred in reducing the punitive damages award. While the court concluded that the district court correctly found that the jury's initial punitive damages award was disproportionate, the court disagreed that the reduced award of $236,500 sufficiently reflected the reprehensibility of defendant's conduct. In this case, the 9:1 ratio comports with due process while achieving the statutory and regulatory goals of retribution and deterrence. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Masters v. Runnels" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's misdemeanor conviction for attempting to purchase a firearm while subject to a protective order, holding that the admission of certain evidence did not violate Defendant's confrontation right.At issue was whether a return of service on a preliminary protective order, which included the serving deputy's signature and the time and date of service, was testimonial evidence subject to exclusion under the Confrontation Clause of the Sixth Amendment to the United States Constitution. The court of appeals concluded that the signing and dating of the return of service was a ministerial duty on the part of the deputy sheriff that was functionally distinct from the delivery of live testimony. The Supreme Court affirmed, holding that the return of service was intended to serve a primarily administrative purpose, not to create an out-of-court substitute for trial testimony, and therefore, the admission of the evidence did not violate Defendant's constitutional right to confrontation. View "Logan v. Commonwealth" on Justia Law

Plaintiff filed suit against the school district, claiming discrimination under the Americans with Disabilities Act (ADA) and the Rehabilitation Act; interference with her Family and Medical Leave Act (FMLA) rights; and retaliation in violation of all three statutes. Principally, plaintiff alleged that, in ending her employment, the school district discriminated against her because she suffers from major depressive disorder and retaliated against her for asserting her statutory rights.The Eleventh Circuit affirmed the district court's grant of summary judgment in favor of the school district. The district court concluded that the school district had terminated plaintiff's employment because of her conduct—the threats she made against her own life and the lives of others—not because she had major depressive disorder or because she had participated in statutorily protected activity. In regard to plaintiff's disability discrimination claims under the ADA and Rehabilitation Act, the court ultimately concluded that plaintiff failed to present sufficient evidence to create a genuine dispute of material fact as to whether the school district's proffered reasons for terminating her employment were pretextual. In regard to plaintiff's retaliation claims, the court concluded that, besides the temporal proximity between when plaintiff asserted her ADA rights and when the school district asked her to resign, no evidence suggests that the school district's stated reasons for ending her employment were merely an excuse to cover up retaliation. In regard to the FMLA interference claim, the court concluded that plaintiff cites nothing from the record to show that the school district's decision to end her employment related in any way to her decision to take FMLA leave. View "Todd v. Fayette County School District" on Justia Law

Jones spent more than 10 years in prison before the Seventh Circuit granted his 28 U.S.C. 2254 habeas corpus petition, finding that he was deprived of his Sixth Amendment right to effective assistance of counsel. After Jones was freed, he filed suit under 42 U.S.C. 1983 against Madison County, Indiana deputy prosecutors Koester and Kopp, in their individual capacities, arguing that they maliciously prosecuted him in violation of his due process rights when they filed an untimely amendment to his charges and secured a conviction. He also alleged that Madison County Prosecutor Cummings, an elected official, adopted and followed an official policy of flouting state-law limitations on amendments to charges. He requested $50 million in general damages for his confinement, compensatory damages for past and future physical and emotional injuries, and attorneys’ fees.The district court dismissed the action, finding that Cummings was a state official, so the suit against him was in substance one against the state. The state is not a “person” that can be sued under section 1983. Jones’s suit against the prosecutors failed because of the absolute immunity prosecutors enjoy when they are acting as advocates. The Seventh Circuit affirmed. Jones was undoubtedly injured by his wrongful imprisonment but that does not mean that he has a remedy against any particular actor. View "Jones v. Cummings" on Justia Law

Plaintiffs, All of Us or None–Riverside Chapter (All of Us or None), Jane Roe, and Phyllis McNeal, filed an action seeking declaratory and injunctive relief against defendants, Superior Court of California, County of Riverside (Riverside Superior Court), and its Executive Officer and Clerk, W. Samuel Hamrick, Jr. Plaintiffs alleged that defendants improperly maintained the Riverside Superior Court’s records in criminal cases in various ways. Plaintiffs alleged that these practices invaded their right to privacy as embodied in the California Constitution (fifth cause of action). Plaintiffs claimed that they were entitled to declaratory relief (sixth cause of action) and writ of mandate (seventh cause of action) to remedy these violations. On appeal, plaintiffs challenged the trial court’s demurrer and summary judgment rulings. The Court of Appeal agreed with Plaintiffs the trial court erred in its ruling on the first, third, and fifth causes of action; as a result, the trial court’s grant of judgment as a matter of law on plaintiffs’ remedial causes of action for declaratory relief (sixth cause of action) and injunctive relief (seventh cause of action) were also reversed. The matter was thus remanded for further proceedings. View "All of Us or None etc. v. Hamrick" on Justia Law