Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's grant of summary judgment to Atrium in an action brought by plaintiff, a former employee, alleging race discrimination, failure to promote, and hostile work environment in violation of the Iowa Civil Rights Act (ICRA). Absent further instruction from the Iowa Supreme Court to the contrary, the court will continue to apply the McDonnell Douglas framework to ICRA discrimination claims at summary judgment.Under the McDonnell Douglas framework, the court concluded that plaintiff failed to present evidence of any situation in which a white Atrium employee took a hotel room out of service, made a key to it, and then allowed unregistered guests to gain possession of the key, without being fired as a result. Furthermore, there is no evidence of white Atrium employees engaging in comparably serious misconduct without experiencing similarly harsh employment consequences. Therefore, the court concluded that plaintiff has not shown that similarly situated employees outside of his protected class were treated more favorably than him after engaging in similar misconduct. The court also concluded that summary judgment on the failure to promote claim was warranted where plaintiff failed to present evidence showing that Atrium's stated reason for declining to promote him was pretextual. Finally, plaintiff's hostile work environment claim failed because he failed to show that he experienced the workplace as abusive or that he felt that the harassment was so severe that it in effect altered the terms of his employment. View "Carter v. Atrium Hospitality" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no reversible error either in any issue raised by Defendant or in this Court's review under Mass. Gen. Laws ch. 33E.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress handwritten note and oral statements he made to officers while he was hospitalized; (2) Defendant was not entitled to reversal of his convictions on the grounds of error in the trial judge's evidentiary rulings; (3) the trial judge did not err in denying Defendant's motion for a new trial; and (4) there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Welch" on Justia Law

The Fifth Circuit withdrew its prior opinion and substituted the following opinion.Plaintiff filed suit against T-Mobile and Broadspire, alleging transgender discrimination under Title VII of the Civil Rights Act of 1964. Plaintiff's claims stemmed from his treatment while working as a retail employee at a T-Mobile store. The court concluded that, at the Rule 12(b)(6) stage, its analysis of the Title VII claim is governed by Swierkiewicz v. Sorema N.A., 534 U.S. 506 (2002)—and not the evidentiary standard set forth in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). Under Swierkiewicz, there are two ultimate elements a plaintiff must plead to support a disparate treatment claim under Title VII: (1) an adverse employment action, (2) taken against a plaintiff because of her protected status. The court explained that when a complaint purports to allege a case of circumstantial evidence of discrimination, it may be helpful to refer to McDonnell Douglas to understand whether a plaintiff has sufficiently pleaded an adverse employment action taken "because of" his protected status as required under Swierkiewicz.Applying these principles here, the court concluded that there is no dispute that plaintiff suffered an adverse employment action. However, the court concluded that plaintiff has failed to plead any facts indicating less favorable treatment than others "similarly situated" outside of the asserted protected class. In this case, the Second Amended Complaint does not contain any facts about any comparators at all, and there is no allegation that any non-transgender employee with a similar job and supervisor and who engaged in the same conduct as plaintiff received more favorable treatment. Therefore, the complaint does not plead any facts that would permit a reasonable inference that T-Mobile terminated plaintiff because of gender identity. Furthermore, plaintiff's Americans with Disabilities Act discrimination claim fails for similar reasons, and plaintiff's retaliation claim under Title VII is untimely.The court rejected plaintiff's contention that Bostock v. Clayton County, 140 S. Ct. 1731 (2020), changed the law and created a lower standard for those alleging discrimination based on gender identity. Rather, the court concluded that Bostock did not constitute an intervening change of law that warrants reconsideration under Rule 59(e). The court explained that Bostock defined sex discrimination to encompass sexual orientation and gender identity discrimination, but did not alter the meaning of discrimination itself. Therefore, where an employer discharged a sales employee who happens to be transgender—but who took six months of leave, and then sought further leave for the indefinite future, that is an ordinary business practice rather than discrimination. Finally, the district court did not abuse its discretion in denying further leave to amend. View "Olivarez v. T-Mobile USA, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion to suppress evidence obtained at the end of a traffic stop, holding that the traffic stop was unlawfully extended after its initial purpose had been resolved.Defendant entered a conditional plea to methamphetamine possession and child endangerment. Defendant appealed, arguing that the district court erred in denying his motion to suppress evidence obtained at the end of the traffic stop because the stop was unlawfully extended before a drug dog alerted. The Supreme Court agreed, holding (1) Defendant did not waive his argument that the stop was unlawfully extended; and (2) Defendant's Fourth Amendment rights were violated because the law enforcement officer unlawfully extended the duration of the traffic stop after he completed the citation. View "Mahaffy v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted second-degree murder, holding that the overwhelming evidence of guilt precluded a conclusion that any alleged errors were prejudicial.On appeal, Defendant argued that his counsel provided ineffective assistance and that the prosecutor committed prejudicial misconduct. The Supreme Court affirmed, holding that the district court did not err in denying Defendant's motion for a new trial due to ineffective assistance of counsel and that prosecutorial misconduct did not deny Defendant a fair trial. Specifically, the Court held that Defendant failed to demonstrate prejudice, which was dispositive of both of his claims. View "Leners v. State" on Justia Law

After plaintiff's murder conviction was vacated when another person confessed to the murder, plaintiff filed suit against the City of Baltimore, the Baltimore Police Department, and others, alleging violations of his federal and state civil rights which led to his wrongful imprisonment for the murder. After a ten-day trial, the jury returned a $15 million verdict in favor of plaintiff. Defendant Goldstein, one of the officers at the scene of the murder, appealed.The Fourth Circuit affirmed the district court's denial of motions for judgment as a matter of law or a new trial under Rules 50 and 59 of the Federal Rules of Civil Procedure, because there was evidence from which a reasonable jury could have found police misconduct. The court found no error in the district court's jury instructions, taken as a whole, because they complied with the law and the district court's earlier rulings. Finally, although the district court improperly admitted hearsay evidence, the error, in the context of the record as a whole, was harmless. Accordingly, the court affirmed the jury's verdict and the district court's denial of Rule 50 and 59 motions. However, the court reversed the district court's dismissal of plaintiff's claim against the Baltimore Police Department under Monell v. Department of Social Services of City of New York, 436 U.S. 658 (1978) where the district court did not explain why the allegations of the complaint that were sufficient earlier no longer were. Rather, the district court's dismissal seems to be based on the verdict issued against Defendant Goldstein. If the City does in fact indemnify Goldstein and the judgment is satisfied, the Monell claim would be moot. View "Burgess v. Goldstein" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court denying Defendant's motion filed under Kan. Stat. Ann. 60-1507 seeking a new trial based on allegations of ineffective assistance of both trial and appellate counsel, holding that Defendant was not entitled to relief on his claims.Defendant was convicted of two counts of aggravated criminal sodomy. His conviction was affirmed on direct appeal. Thereafter, Defendant brought this motion seeking a new trial based on allegations of ineffective assistance of both his trial counsel and appellate counsel. The district court denied the motion. The court of appeals reversed. The Supreme Court reversed, holding (1) the district court's findings of fact were supported by substantial competent evidence; (2) the findings of fact supported the district court's legal conclusion; and (3) Defendant received effective assistance of counsel during both his trial and during appellate proceedings. View "Khalil-Alsalaami v. State" on Justia Law

Four years after his release from prison, and after completing three years of supervised release, plaintiff was told he would have to serve another 27 months in jail based on an erroneous release from prison because he had a consecutive misdemeanor to serve. Plaintiff filed a writ of habeas corpus and the district court ruled that he must serve the remainder of his sentence. Plaintiff appealed, but the district court failed to act on the appeal until December 2013, at which point it dismissed the petition as moot because plaintiff had been released from jail upon completion of his sentence.Plaintiff then filed a 42 U.S.C. 1983 action alleging that his spontaneous incarceration deprived him of due process under the Fifth Amendment. The district court dismissed the case based on claim preclusion in light of plaintiff's prior unsuccessful habeas corpus action. The DC Circuit reversed and, on remand, the district court granted summary judgment for the District.The DC Circuit affirmed the district court's judgment that plaintiff failed to establish a pattern of constitutional violations or to demonstrate deliberate indifference. The court explained that plaintiff's evidence fails to show either that the District had a relevant custom of unconstitutional actions or that the District acted with deliberate indifference. However, the court vacated the entry of summary judgment for the District on the claim of unconstitutional policy because the nature and contours of the alleged policy present a number of disputed issues of material fact. Accordingly, the court remanded for further proceedings. View "Hurd v. District of Columbia" on Justia Law

The Supreme Court reversed Defendant's conviction of operating while intoxicated (OWI), holding that Mitchell v. Wisconsin, 588 U.S. __, __, 139 S. Ct. 2525 (2019) (plurality opinion), applies to cases of suspected driving while under the influence of controlled substances, in addition to alcohol-related cases.Defendant caused an accident while driving recklessly. Defendant, who was injured, was taken to the hospital strongly smelling of marijuana. A police officer dispatched to the hospital performed a blood test of Defendant, who was sedated, after a medical professional certified that Defendant was unable to consent or refuse blood testing. Defendant filed a motion to suppress the testing, but the motion was overruled. Defendant appealed, arguing that the warrantless blood draw violated Iowa Code 321J.7, the Fourth Amendment to the federal Constitution, and Iowa Const. art. I, 8. The Supreme Court reversed, holding (1) the State complied with section 321J.7; (2) because the parties did not have an opportunity to make a record under the Mitchell standard, the case must be remanded; and (3) article I, section 8 does not provide greater protection from warrantless blood draws than the Mitchell standard. View "State v. McGee" on Justia Law

In 2012, Grzegorczyk hired two men to kill his ex-wife and others whom he deemed responsible for his divorce and the loss of custody of his son. The men he hired were undercover law enforcement officers. During a final meeting, Grzegorczyk gave the undercover officers $3,000 in cash, and showed them pictures, $45,000 in cash that he intended to pay upon completion of the murders, a semi-automatic handgun, and ammunition. Grzegorczyk was arrested.In 2014, Grzegorczyk pled guilty to murder-for-hire, 18 U.S.C. 1958(a) and possession of a firearm in furtherance of a crime of violence, 18 U.S.C. 924(c)(1)(A)., Grzegorczyk waived the right to “all appellate issues that might have been available if he had exercised his right to trial”; he could only appeal the validity of his guilty plea and the sentence imposed. The district court imposed a within-Guidelines sentence of 151 months, with consecutive 60 months for the firearm offense, which was affirmed on appeal. The Supreme Court then invalidated the definition of a “violent felony” under the residual clause of the Armed Career Criminal Act, 18 U.S.C. 924(e)(2)(B)(ii) (Johnson decision), later extending the holding to section 924(c)'s residual clause definition of “crime of violence.”Grzegorczyk sought relief under 28 U.S.C. 2255 from his 924(c) conviction. The district court denied relief. The Seventh Circuit affirmed. Grzegorczyk has long unconditionally waived his right to contest the validity of his plea agreement and the legal sufficiency of the 924(c) charge. View "Grzegorczyk v. United States" on Justia Law