Justia Civil Rights Opinion Summaries

The Supreme Court dismissed on direct appeal the order of the circuit court denying in part Monsanto Company's motion for judgment on the pleadings and concluding that the Arkansas State Plant Board's Regulation 7 does not violate the Commerce Clause of the federal Constitution and is not invalid as being enacted by an unconstitutionally appointed board, holding that the circuit court did not err.The circuit court denied Monsanto's motion challenging the constitutionality of Regulation 7 and further granted judgment in favor of Monsanto on its claim that Ark. Code Ann. 2-16-206, the statute governing appointment of Board members, is an unconstitutional delegation of the appointment power. The Supreme Court dismissed on direct appeal and affirmed on cross-appeal, holding (1) the circuit court did not err in ruling that Regulation 7 does not violate the Commerce Clause or in rejecting Monsanto's argument that Regulation 7 was enacted by an unconstitutionally appointed board; and (2) the circuit court properly ruled that section 2-16-206(a)(5)-(13) is an invalid delegation of the appointment power. View "Monsanto Co. v. Arkansas State Plant Board" on Justia Law

Plaintiff appealed the district court's dismissal based on lack of standing of his claims against the City under Title II of the Americans with Disabilities Act (ADA) of 1990 and section 504 of the Rehabilitation Act of 1973.The Eleventh Circuit reversed and remanded for further proceedings, concluding that the district court erred in relying on the test articulated in Price v. City of Ocala, 375 F. Supp. 3d 1264 (M.D. Fla. 2019), to determine if plaintiff suffered an injury in fact. The court explained that Price is a district court opinion, and thus it does not constitute binding precedent. Even if the court were bound by it, Price is unhelpful here because it is fundamentally different from this case. The court also concluded that the district court erred in finding that plaintiff did not have standing. Rather, plaintiff has standing to bring his claim under Title II, as he adequately alleged a stigmatic injury. In this case, plaintiff, as an individual with a disability, was personally and directly subjected to discriminatory treatment when the City published videos on its website that he accessed but could not understand. Therefore, he suffered a concrete and particularized injury. View "Sierra v. City of Hallandale Beach" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 alleging that officials at the Monroe County Jail denied him adequate medical care and subjected him to cruel and unusual punishment during his pretrial confinement. Plaintiff was ultimately admitted to the hospital where he was found to be in critical condition and was placed in a coma for over a month where he underwent serious surgeries. After his grievance was denied by the prison, plaintiff argued that administrative procedures were unavailable to him because he was hospitalized and in critical medical condition for over a month and therefore could not have filed a grievance within that five-day timeframe.The Second Circuit reversed, concluding that administrative remedies are "unavailable" when (1) an inmate's failure to file for the administrative remedy within the time allowed results from a medical condition, and (2) the administrative system does not accommodate the condition by allowing a reasonable opportunity to file for administrative relief. In this case, administrative remedies were unavailable to plaintiff because he was hospitalized and in a critical medical condition during—and well past—the five-day timeframe to file a grievance according to the jail's grievance procedures. Furthermore, the prison made clear that it would not process any grievance filed past that five-day timeframe. Accordingly, the court remanded for the district court to consider plaintiff's claim on the merits. View "Rucker v. Giffen" on Justia Law

Plaintiff filed suit against the Alabama Deputy Fire Marshal and several law enforcement officers, ATF Agents, and other unnamed officers, alleging claims related to a fire inspection the Fire Marshal performed on plaintiff's nightclub.The Eleventh Circuit affirmed the district court's dismissal of plaintiff's claims against the ATF Agents and the entry of summary judgment for the Fire Marshal. The court concluded that the district court's reliance on the suppression-hearing transcript was proper and that it committed no error in finding that the Fire Marshal was entitled to qualified immunity. In this case, a reasonable officer in the Fire Marshal's position could have believed that he had plaintiff's effective consent to enter the club to conduct an inspection. Furthermore, the Fire Marshal was entitled to qualified immunity for his search of plaintiff's bedroom. The court also concluded that it lacked personal jurisdiction over the individual-capacity claims against the ATF Agents because they were improperly served, and the official-capacity claims against them are barred by sovereign immunity. View "Fuqua v. Turner" on Justia Law

The Supreme Judicial Court reversed the order of the trial judge denying Defendant's motion to continue his evidentiary hearing on his motion to suppress until it could be held in person, holding that the trial judge abused her discretion.Defendant, who was charged with a drug offense, filed a motion to suppress evidence and statements. After the suppression hearing was postponed for a third time because of the COVID-19 pandemic the judge ordered that the hearing take place via Zoom. Defendant filed a motion objecting to the Zoom hearing and requested that the case be continued until an in-court hearing could be held safely. The judge denied the motion. The Supreme Judicial Court reversed, holding that because Defendant waived his right to a speedy trial and there were no civilian victims or witnesses, the trial judge abused her discretion in denying Defendant's objection to conducting the evidentiary hearing on his motion to suppress via Zoom video conference. View "Diaz v. Commonwealth" on Justia Law

Plaintiff filed a handwritten, pro se 42 U.S.C. 1983 complaint against defendant, an assistant warden, alleging that he had received threats from "a sexually violent predator inmate" on his cell block. A committee, chaired by defendant, denied plaintiff's transfer requests and, about a month later, plaintiff was attacked by the inmate who had previously threatened him. Plaintiff filed suit alleging that defendant violated his Eighth Amendment rights by deliberately failing to protect him, seeking a preliminary injunction and damages.The Fifth Circuit vacated the district court's dismissal of the action and remanded to the district court for consideration of the merits of plaintiff's allegations in the first instance, as well as any response from the assistant prison warden. In this case, although the complaint did not specifically allege what defendant knew, it does allege that defendant called plaintiff a "snitch" and denied him a transfer for that reason. The court concluded that plaintiff was entitled to have his allegations addressed by the district court in the first instance. View "Alvarez v. Akwitti" on Justia Law

An Illinois jury convicted Evans of the first-degree murder of Williams, who was killed in a Chicago drive-by shooting. Only one eyewitness, Jeffers, connected Evans to the shooting. Jeffers initially only provided a few general identifying details of the shooter and did not specifically identify any shooter. Eleven months later, the police approached him while he was incarcerated; Jeffers then identified Evans as the shooter. At trial, Jeffers recanted that identification: he testified that he did not see the identity of the shooter but had identified Evans because the police told him to. During closing arguments, the prosecutor argued that Jeffers’s trial testimony was false and the jury should disbelieve it because Jeffers only changed his story after being paid a visit by a defense investigator working for Evans’s co-defendant, who was a known gang member.The state appellate court concluded that there was sufficient evidence to support the prosecutor’s closing argument statements, so they were not improper. Evans unsuccessfully sought state post-conviction relief.The Seventh Circuit affirmed an order granting federal habeas relief. The state appellate court’s determination that the prosecutor’s statements were proper was objectively unreasonable. The facts compel the conclusion that Evans was deprived of his right to a fair trial. View "Evans v. Jones" on Justia Law

The Supreme Court dismissed Defendant's conviction, entered after a second trial, for sexual intercourse without consent and bail jumping, holding that the district court abused its discretion in declaring and mistrial and erred in concluding that double jeopardy did not bar Defendant's retrial.Defendant was originally charged with incest and a jury was impaneled. Nearing the conclusion of the State's case the court reporter had either a heart attack or a stroke and was taken to the hospital. The court declared a mistrial, and a retrial was scheduled. Before the second trial, the State amended its charge to correct a deficiency in the original charging documents. Defendant was subsequently convicted. The Supreme Court reversed, holding (1) Defendant's subsequent prosecution for sexual intercourse without consent and bail jumping for the same incident as his first prosecution was barred by the United States and Montana Constitutions protections against double jeopardy; and (2) the district court abused its discretion in declaring a mistrial. View "State v. Newrobe" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony theft by possession of stolen property and four misdemeanor, holding that Defendant was not entitled to relief on any of his claims of error.Specifically, the Supreme Court held (1) the district court acted within its discretion in denying Defendant's motions for mistrial after two separate references to Defendant's "jail" status were made by State witnesses; (2) the district court did not err in declining to give a jury instruction on unauthorized use of a motor vehicle as a lesser-included offense of the charged theft by possession of stolen property; and (3) Defendant's ineffective assistance of counsel claims would more appropriately be addressed through a petition for postconviction relief. View "State v. Denny" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of extreme atrocity or cruelty, holding that there was no error that would require reversal of Defendant's convictions.Defendant's first trial ended in a mistrial because the jury were unable to reach a verdict. After a retrial, Defendant was convicted of murder. On appeal, Defendant challenged the trial court's denial of his motion to suppress his cell site location information (CSLI) and any "fruits" derived from it. The Supreme Judicial Court affirmed, holding (1) law enforcement infringed upon Defendant's reasonable expectation of privacy in his CSLI without a warrant, but the error was harmless; (2) trial counsel was not ineffective for failing to instruction to certain portions of the jury instructions; and (3) Defendant was not entitled to relief on his remaining claims of error. View "Commonwealth v. Gumkowski" on Justia Law