Justia Civil Rights Opinion Summaries

The Supreme Court vacated the judgment of the family court convicting Defendant of cruelty to or neglect of a child and sentencing her to a one-year suspended term of imprisonment, with probation, holding that a new trial was required.On appeal, Defendant argued that the trial justice erred by proceeding with a bench trial without obtaining a knowing, intelligent, and voluntary waiver of Defendant's right to a jury trial and erred in finding habitual neglect in this case. The Supreme Court vacated the judgment below, holding that because there was nothing in the record indicating that the trial justice was assured by Defendant that her waiver of a jury trial was made intelligently and with full knowledge of the consequences of her waiver, the case must be remanded for a new trial. View "State v. Michaud" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for two counts of murder in the first degree and the denial of his motion for a new trial, holding that Defendant was not deprived of his constitutional right to the effective assistance of counsel.On appeal, Defendant argued, among other things, that it was manifestly unreasonable for his trial counsel to forgo mental health defenses in favor of a third-party culprit defense. The Supreme Judicial Court disagreed, holding (1) trial counsel was not ineffective for urging one defense over the other, and Defendant was not prejudiced by his trial counsel's performance; and (2) there was no basis upon which to exercise the Court's extraordinary authority to order a new trial or to reduce the verdicts pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Velez" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Defendants - various prison officials, the Massachusetts Department of Correction (DOC), and Plaintiff's prison physician - and dismissing Plaintiff's complaint for injunctive and declaratory relief and damages, holding that there was no error in the proceedings below.Plaintiff, an inmate at MCI-Concord in Massachusetts, brought this pro se complaint challenging the termination of his access to the prison's first-floor Lexis Nexis terminal and typewriter, where Plaintiff spent more than two years conducting legal research and creating legal documents. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding (1) Plaintiff's speculative arguments as to the summary judgment in favor of his prison doctor were not enough to summary judgment; (2) the district court properly found that the DOC defendants' legitimate explanations were not pretextual; and (3) the district court did not err in determining that there was no triable issue of material fact that Defendants subjected Plaintiff to cruel and unusual punishment by discontinuing Plaintiff's reliance upon the first-floor terminal. View "Snell v. Neville" on Justia Law

After plaintiff, a York County Sheriff's Office (YCSO) employee, disclosed confidential information about an ongoing investigation into an inmate's death to his wife, who worked at a local news station, and then lied to internal investigators about the disclosure, defendant terminated plaintiff's employment. Plaintiff filed suit against defendant under 42 U.S.C. 1983, alleging that he was fired in retaliation for exercising his First Amendment rights. The district court ruled in favor of plaintiff, but the Fourth Circuit vacated and remanded. On remand, the district court concluded that plaintiff's speech was not protected speech after applying the proper standard. The district court found the speech in question caused a reasonable apprehension of disruption in the YCSO and that defendant's interest in avoiding such a disruption outweighed plaintiff's circumstantially diminished First Amendment interest. Plaintiff appealed, challenging the district court's balancing of the parties' interests.The Fourth Circuit afforded diminished weight to plaintiff's First Amendment interest and concluded that it was outweighed by defendant's reasonable apprehension of disruption. In this case, plaintiff acted on limited and unconfirmed information when disclosing confidential details, and did so knowing that an investigation into the incident was underway, making no effort whatsoever to proceed through the chain of command or any law enforcement channel. Furthermore, the record reveals a reasonable apprehension of disruption in the YCSO, particularly considering plaintiff's speech propelled a frenzy of media attention about unconfirmed facts related to the inmate's death. The court explained that the disruption ballooned into separate internal investigation into the unauthorized disclosure, undercutting manpower and resources to continue the ongoing investigation into the incident. Accordingly, plaintiff's First Amendment retaliation claim failed and the court affirmed the district court's judgment. View "Billioni v. Bryant" on Justia Law

In 1982, Thompson was convicted of two counts of murder and one count of conspiracy to commit burglary for his role in the home invasion and killing of the Hilborns. After a remand for resentencing, the Indiana Supreme Court affirmed his sentence of two consecutive 60-year terms for the murders and a consecutive 30-year term for the conspiracy to commit burglary. Thompson filed a post-conviction petition that languished until 2015; the Indiana Court of Appeals affirmed the denial of relief.Thompson filed a federal habeas petition, alleging ineffective assistance of counsel by failing to move to suppress Thompson’s request for a lawyer and his post-request statements, failing to object to the prosecutor’s closing argument remarks referencing Thompson’s request for a lawyer, and failing to present the prosecutor’s remarks in Thompson’s direct appeal. Following a remand, the district court dismissed the petition.The Seventh Circuit affirmed. It is not “substantially” likely that the result of Thompson’s trial or appeal would have been different but for his counsel’s actions. The physical evidence and eyewitness testimony were consistent with testimony by his co-conspirator, Dillon, implicating Thompson, including blood on Thompson’s jeans and gloves that law enforcement recovered from his closet shortly after the murders; the hunting knife found in Thompson’s trunk, freshly cleaned and oiled; Thompson’s presence with Dillon at a laundromat just after the murders; and the forensic pathologist’s testimony about the Hillborns's stab wounds. The evidence against Thompson was “overwhelming.” View "Thompson v. Vanihel" on Justia Law

The Supreme Court affirmed the decision of the Board of Tax Appeals (BTA) affirming the City of Cleveland's taxation of Hazel Willacy's stock-option income that she realized in 2016, holding that Willacy's propositions of law lacked merit.Willacy earned the disputed stock options in 2007 from her former employer while she was working in Cleveland. In 2009, Willacy retired and moved to Florida without having exercised any of the options. In 2014 and 2015, Willacy exercised the majority of the options and immediately resold the shares. In 2016, Willacy exercised the remaining options. Her former employer withheld her municipal-income-tax obligation and paid it to Cleveland. Willacy sought a refund on the grounds that she did not live or work in Cleveland. The refund was denied, and the BTA affirmed the denial. The Supreme Court affirmed, holding that Cleveland's taxation of Willacy's 2016 compensation was required under municipal law and did not violate her due process rights under either the United States or Ohio constitutions. View "Willacy v. Cleveland Board of Income Tax Review" on Justia Law

The Fifth Circuit affirmed the district court's dismissal of plaintiff's complaint pursuant to Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971), claiming that various prison officials violated his constitutional rights by tampering with his meals and denying his grievance.The court concluded that, even if plaintiff's claims were timely, they must be dismissed. The court declined to extend Bivens to include First Amendment retaliation claims against prison officials, joining its sister courts that have recently considered the matter. In this case, although plaintiff asserts Bivens claims against the food administrators and foremen under the First Amendment, Fifth Amendment, and Eighth Amendment, his claims are best construed under the First Amendment since he claims that defendants retaliated against him for filing grievances. Because plaintiff's claims appear nothing like the Bivens trilogy, the court concluded that his claims arise in a new context. Furthermore, this case presents special factors counseling hesitation. The court explained that Congress should decide whether to provide for a damages remedy. Finally, the court concluded that the district court did not err in dismissing plaintiff's claims against the administrative remedy coordinators where, even if plaintiff had a viable Bivens claims, vicarious liability is inapplicable to Bivens suits. Because he failed to assert standalone claims against the administrative remedy coordinators, plaintiff's claims against them must be dismissed. View "Watkins v. Three Administrative Remedy Coordinators of the Bureau of Prisons" on Justia Law

In 2006, Reyes was convicted of several federal crimes stemming from the armed robbery of a credit union, including brandishing a firearm in furtherance of a “crime of violence,” 18 U.S.C. 924(c)(1)(A), He was sentenced as a career offender based on his prior convictions for burglary, voluntary manslaughter, and attempted murder under Illinois state law. After Reyes was convicted, the Supreme Court issued decisions interpreting statutory definitions of “crime of violence,” holding that “residual clauses” in several statutes are unconstitutionally vague. In 2016, Reyes brought a second collateral attack under 28 U.S.C. 2255, asserting that this emerging case law rendered his conviction and sentence unconstitutional. The district court denied relief but issued a certificate of appealability concerning the conviction for brandishing a firearm.The Seventh Circuit affirmed. The jury was properly instructed. The instruction did not treat Reyes’ conspiracy conviction as a predicate for his colleagues’ brandishing of the firearm. That the brandishing (and robbery) occurred in furtherance of the conspiracy was a necessary but not sufficient condition for Reyes’ conviction under section 924(c). The instruction explained that the government still had to prove beyond a reasonable doubt that Reyes’ colleague brandished the gun in furtherance of a crime of violence--the robbery. View "Reyes v. United States" on Justia Law

The Supreme Court affirmed Defendant's convictions for the first-degree murder and robbery of a deputy sheriff and his sentence of death, holding that Defendant's claims of error lacked merit.Specifically, the Supreme Court assumed error, but found no prejudice, as to (1) the trial court's failure to give a pinpoint jury instruction on Defendant's claim of accident relating to a felony-murder special-circumstance allegation; (2) the admission of a photograph of Defendant at the time of his prior sexual assault of Diane K.; and (3) the admission of certain victim impact testimony. Further, the trial court committed harmless error by using the 1996 revised version of CALJIC No. 8.71. The Court held that the cumulative effect of the three assumed error and the one harmless error did not warrant reversal. The Court remanded the matter for resentencing to strike a three-year prison term enhancement and otherwise affirmed. View "People v. Scully" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims against the Board of Regents of the University of Minnesota, alleging that the University constructively terminated her and subjected her to a hostile work environment. Plaintiff, the head coach of the women's cross-country and track-and-field teams, resigned after the University threatened to terminate her following an outside-law-firm's investigation into her alleged misconduct.The court concluded that, although plaintiff's factual allegations show the University treated her and her teams differently from other coaches and teams, the complaint does not plausibly give rise to the inference of discrimination on the basis of sex as the reason for her termination. Furthermore, even if the stated reason for her termination was pretextual, she has not stated a claim for relief that is plausible on its face. The court also concluded that plaintiff's allegations, though perhaps describing vile or inappropriate behavior, do not rise to the level of actionable hostile work environment as a matter of law. View "Warmington v. Board of Regents of the University of Minnesota" on Justia Law